th july, 2018environmentclearance.nic.in/writereaddata/online/... · jagatpur, ahmedabad by godrej...

20th July, 2018

Ministry of Environment, Forest and Climate Change Indira Paryavaran Bhawan Jor Bagh Road New Delhi–110 003

Subject: Environmental Clearance for proposed Balance Area Construction in Godrej Garden City at Jagatpur, Ahmedabad by Godrej Properties Ltd. IA/GJ/MIS/66174/2016; File No. [F. No. 21-260/2017-IA-III] Submission of additional information – Minutes of the 31st Meeting of Expert Appraisal Committee (Infra 2) held on 29-30 May, 2018 – Item No. 31.4.5

Kind Attn.: Member Secretary

Dear Sir With reference to the above subject, kindly find enclosed the additional information sought by EAC. We believe that you will find the above mentioned submission in order and consider the project for Environmental Clearance. Thanking You Yours truly

For Godrej Properties Limited Authorized Signatory

Annex I 31st EAC Minutes of Meeting

Minutes of the 31st Meeting of Expert Appraisal Committee (Infra-2) held on 29-30 May, 2018

Page 1 of 76

Minutes of the 31th

Day 1: Tuesday, 29

Meeting of Expert Appraisal Committee (Infra-2) for Projects related to All Ship Breaking Yard including Ship Breaking Unit, Airport, Common Hazardous Waste Treatment, Storage and Disposal Facilities, Ports and Harbours, Aerial Ropeways, CETPs, Common Municipal Solid Waste Management Facility, Building/Construction Projects, Townships and Area Development Projects held on 29-30 May, 2018 in the Ministry of Environment, Forest and Climate Change, Indira Paryavaran Bhawan, New Delhi – 3.

th

May, 2018

31.1 Opening Remarks of the Chairman At the outset, Chairman welcomed the members of the Expert Appraisal Committee (Infra-2). Thereafter, agenda items were taken up for discussion. The deliberations held and decisions taken are as under.

31.2 Confirmation of the Minutes of the 30th

The minutes of the 30

Meeting of the EAC held on 18-20 April, 2018 at New Delhi.

th

31.3 Consideration of Proposals Meeting of the EAC held on 18-20 April, 2018 were confirmed.

31.3.1 Common Effluent Treatment Plant (CETP) at Tripura Mega Food Park, Tulakona ,

West Tripura, Tripura by M/s Sikaria Mega Foodpark Private Limited - Reconsideration for Terms of Reference (IA/TR/MIS/73629/2018; F.No. 10-25/2018-IA-III)

The project proponent and the Consultant M/s Shri Environmental Technology Institute, New Delhi gave a detailed presentation and informed the Committee that:

(i) The proposed project is to establish 1000 KLD capacity Common Effluent Treatment Plant (CETP) at Tripura Mega Food Park, Tulakona Industrial Estate, Tulakona & Uttar Champramura Mouza, Dist: West Tripura, Tripura. This CETP will be established and operated by “Sikaria Mega Foodpark Private Limited”. The Latitude and Longitude is given as 23°48'40.76"N, 91°20'49.67"E

(ii) The land has been taken on lease from Tripura Industrial Development Corporation Limited, A Government of Tripura Undertaking, for a period of 35 years. The industrial effluents from the units being set up in Mega Food Park, will be treated in the proposed CETP. For the proposed CETP, 35 numbers of Units are considered.

(iii) The treated effluent after conforming to the specified/notified standards will be reused and recycled to the maximum extent. The remaining treated effluent will be used for tree plantation, landscaping, irrigation, HVAC and sprinkling for dust suppression in the surroundings and excess will be discharged into river with prior permission.

(iv) Technical Specifications of the CETP are as follows:

Source of Waste Water Food Processing Units Effluent & Sewage Plant Treatment Capacity (KLD/day) 1 MLD


5 of 76

31.4.4 Anand Lok Affordable Group Housing at Village Godhan, Tehsil Tijara, Alwar, Rajasthan by M/s One City Infrastructure Pvt Ltd - Reconsideration for Environmental Clearance ( IA/RJ/NCP/73673/2018; F.No. 21-17/2018-IA-III)

The EAC noted the following:-

(i) The proposal is for grant of environmental clearance to the project ‘Anand Lok Affordable Group Housing at Village Godhan, Tehsil Tijara, Alwar, Rajasthan by M/s One City Infrastructure Pvt Ltd in a total plot area of 11,335.85 sqm and total construction (built-up) area of 24,974.68 sqm.

(ii) The project/activity is covered under category ‘B’ of item 8(a) ‘Building and Construction Projects’ of the Schedule to the EIA Notification, 2006 and its subsequent amendments, and requires appraisal at State level. However, due to absence of SEIAA/SEAC in Rajasthan, the proposal is appraised at Central Level.

(iii) The proposal was earlier considered in 30th

(iv) The Project Proponent submitted the additional information on Ministry’s website on 14.05.2017.

Meeting held on 29-30 April, 2017. The EAC asked the project proponent to submit more details.

The committee deliberated upon the information provided by the project proponent. It was noted that the water balance and other details provided by the project proponent was not in order. The Committee was not satisfied with the submission of project proponent and ask project proponent to submit the following details/documents:

(i) Submit revised water balance details of the project. (ii) The application made/permission of the CGWA for abstraction of ground water. (iii) A detailed report on compliance to ECBC-2017 norms. (iv) Plan for Corporate Environment Responsibility (CER) as specified under Ministry’s

Office Memorandum vide F.No. 22-65/2017-IA.III dated 1st

The proposal was, therefore, deferred till the desired information is submitted.

May 2018 shall be prepared and submitted.

31.4.5 Balance area construction in Godrej Garden City, Ahmedabad By Godrej Properties Limited - Reconsideration for Environmental Clearance (IA/GJ/MIS/66174/2016

The EAC noted the following:-

; F.No. 21-260/2017-IA-III)

(i) The proposal is for grant of environmental clearance to the project “Balance area construction in Godrej Garden City, Ahmedabad By Godrej Properties Limited in a total plot area of 8,37,643.00 sqm and built-up area of 21,55,307 sqm.

(ii) The project/activity is covered under item 8(b) ‘Townships and Area Development Projects’ of the Schedule to the EIA Notification, 2006.

(iii) The project was granted ToR by SEAC, Gujarat vide letter No. EIA-10-2015-7207-E-711 dated 23.03.2016.


Page 46 of 76

(iv) The proposal was earlier considered in 21st

(v) The Project Proponent submitted/uploaded the additional information on Ministry’s website on 16.12.2017.

Meeting held on 21-24 August, 2017, wherein the Committee sought additional information.

The EAC deliberated on the proposal including Certified Compliance Reports letter No. 18-A-255/2012(SEAC/1337,1338 & 1339 dated 30.11.2017 issued by the MoEF&CC’s Regional Office (Western Region), Bhopal. The Committee noted that there are several conditions which are complied subject to additional input, partly complied and not complied. A show-cause notice was issued by Gujarat Pollution Control Board to the project proponent on 02.07.2016. After detail deliberation, the Committee sought following details:

(i) Status of show cause notice dated 02.07.2016. (ii) Submit an action taken report on issues which have been stated to be partially

complied or not complied in the Certified Compliance Reports issued by MoEFCC, Regional Office, Bhopal.

(iii) Plan for Corporate Environment Responsibility (CER) as specified under Ministry’s Office Memorandum vide F.No. 22-65/2017-IA.III dated 1st

The proposal was, therefore, deferred till the desired information is submitted.

May 2018 shall be prepared and submitted.

31.4.6 Development of the facilities envisaged in the Port Master Plan (phase III) of M/s Kamarajar Port Limited - Reconsideration for Environmental and CRZ Clearance (IA/TN/MIS/31769/2015 ; F.No. The EAC noted the following:-

11-51/2012-IA-III)

(i) The proposal is for grant of Environmental and CRZ Clearance to the project ‘Development of the facilities envisaged in the port master plan (Phase III) of M/s Kamarajar Port Limited

(ii) The project/activity is covered under category ‘A’ of item 7 (e) i.e. Ports, harbours, break waters, dredging’ of the schedule to the EIA Notification, 2006 and its subsequent amendments, and requires appraisal at Central level.

.

(iii) The proposal was earlier considered in 21st

(iv) The Project Proponent submitted the additional information vide letter dated 26.09.2017 and uploaded on Ministry’s website on 28.09.2017.

Meeting held on 21-24 August, 2017 wherein the Committee sought some additional information including Certified Compliance Report of the conditions stipulated in the earlier environmental clearances issued for the project.

(v) The proposal was earlier considered in 25nd

(vi) The sub-committee visited the site on 5-6 January, 2018 and submitted its report vide e-mail dated 16.04.2018 and handed over to the Chairman, EAC (Infra-2)

Meeting held on 29-30 November, 2017. In view of the representations received in the Ministry and also forwarded to the Committee Chairman and Members, the committee recommended that a sub-committee consisting of Mr. K. Gowrappan and Dr. Ayi Vaman N. Acharya, Member of the EAC(Infra-2) should be deputed to visit the site and give its report for further deliberation.

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Query Reply

Godrej Garden City, Ahmedabad EAC submission to the points raised

Submission to the Expert Appraisal Committee (EAC), Infra-2 on the additional information sought during the 31st EAC meeting held on 30th May, 2018 for our project – “Proposed Balance Area Construction in Godrej Garden City at Jagatpur, Ahmedabad” by Godrej Properties Ltd. IA/GJ/MIS/66174/2016; File No. [F. No. 21-260/2017-IA-III]

Point 1

Status of show cause notice dated 02.07.2016

Our Submission

The Show Cause Notice by GPCB was to know whether there is EC violation - Construction beyond the built up mentioned in the ECs obtained. Reply was submitted on 8th July 2016 clarifying the issue and the reply downloaded from GPCB XGN is enclosed as Annex II.

Point 2

Submit an action taken report on issues which have been stated to be partially complied or not complied in the Certified Compliance Reports issued by MoEF&CC, Regional Office, Bhopal

Our Submission

The action plan taken by us against the partially complied and non-complied EC conditions mentioned in the Certified Compliance Report is enclosed as Annex III.

Point 3 Plan for Corporate Environment Responsibility (CER) as specified under Ministry’s Office Memorandum vide F. No. 22-65/2017-IA.III dated Ist May 2018.

Our Submission

CER commitment for the project (per OM (No. 22/65/2017/-IA.III) dated 1st May, 2018) is attached as Annex IV.

Annex II Reply to Show Cause Notice

GUJARAT POLLUTION CONTROL BOARDPARYAVARAN BHAVAN

Sector 10-A, Gandhinagar 382 010Phone : (079) 23226295Fax . (079) 23232156Website :www.gpcb.gov.in

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Annex I

A. Any Specific Information Called for [in SCRUTINY] (000) Uploaded in XGN on 12/07/2016 18:09:51 from IP No: 117.222.76.218.B. 34230-Godrej Garden City accepts the LEGAL responsibility and undertakes that the furnished information is CORRECT & ACCURATE.

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GUJARAT POLLUTION CONTROL BOARDPARYAVARAN BHAVAN

Sector 10-A, Gandhinagar 382 010Phone : (079) 23226295Fax . (079) 23232156Website :www.gpcb.gov.in

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Annex I


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Office : Gujarat Pollution Control Board, “Paryavaran Bhavan” Sector-10 A, Gandhinagar-382010

Phone No.:- (079) 232-32152,232-41514 Fax No.:-(079) 232-22784 E-mail : [email protected], Website:- www.seiaa.gujarat.gov.in

STATE LEVEL ENVIROONMENT R.G.SHAH IMPACT ASSESSMENT

MEMBER SECRETARY AUTHOORITY SEIAA (GUJARAT) GUJARAT Government of Gujarat

No. SEIAA/GUJ/EC/8(b)/ /2010 Date: Time Limit

Sub: Environment Clearance for proposed Phase-I of the Township Project at Survey No. 54/P,44,108,46,43,82,83,92,66/P,29,15/P,33,16, Village : Jagatpur, Ta: Dascroi, Dist: Ahmedabad by M/s. Godrej Properties Ltd.,…..in Category 8 (b) of Schedule annexed with EIA Notification dated 14/9/2006.

Dear Sir, This has reference to your application along with Form-I, EIA Report and Addition details submitted to SEAC, seeking Environmental Clearance under Environment Impact Assessment Notification, 2006.

The proposal is for Environmental Clearance for proposed Phase-I of the Township Project by M/s Godrej

Properties Ltd., Survey No. 54/P,44,108,46,43,82,83,92,66/P,29,15/P,33,16, Village : Jagatpur, Ta: Dascroi, Dist: Ahmedabad. The proposed township at Jagatpur, Ahmedabad. The plot area of the project is 10,88,596 sq.m. (269 Acre). The project falls under the category 8(b) of EIA Notification-2006. The township shall be developed in a phased manner. The proposed built up area for all the six phases of entire township is 24,68,809 sq.m. The proposal is for development of the area as a self contained township consisting of residences, Economical Weaker Section [EWS] housing, commercial and retail spaces, institutional and other leisure facilities. The township is conceptualized as mixed use development distributed in three sectors A, B and C. The residential buildings are proposed for a height of 43.30m. Scope of the buildings will be Ground + 12 floors. For the first phase, plot area shall be 56489.36 sq.m. and built up area shall be 104343 sq.m. First phase shall consist of residential buildings only. The residential buildings are proposed for a height of 43.30 m. Scope of the buildings will be Ground + 12 floors. Residential population is estimated as 5376 for Phase I. Infrastructure proposed for the first phase shall include:

STP for treatment and recycling of waste water generated in the operational phase. Rainwater harvesting through ponds with recharging structures with tube-wells. Development of approach road (external road) and internal roads for onsite traffic movement as well as

walkways for pedestrian movement. Parking space. Energy efficient electrical installation for conserving electricity. Green belt development including soft landscaping, gardens etc,

The project activity is covered in 8(b) and is of ‘B’ Category. Since the proposed project is in item no.8 of the EIA notification, 2006, it does not need Public Consultation as per Para 7(i) III. Stage (3) (d) – Public Consultation of EIA Notification, 2006. The SEAC, Gujarat had recommended to the SEIAA, Gujarat, to grant the Environment Clearance to this project for the above-mentioned project. The proposal was considered by SEIAA, Gujarat in its meeting held on 29.11.2010 at Gandhinagar. Since the EIA was found to be adequate and complete and the public consultation is not required for the project, the SEIAA hereby accords Environmental Clearance to above project under the provisions of EIA Notification dated 14th September, 2006 subject to the compliance of the following Specific and General conditions.

Annex II


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A. SPECIFIC CONDITIONS: 1. This recommendation is for development of first phase of the project involving plot area of 56489.36 sq.m.,

built up area of 104343 sq.m. and construction of residential buildings (Ground + 12 floors) only. The project proponent shall have to separately approach to SEAC / SEIAA for environmental clearance for the remaining phases of the project as and when proposed.

2. The project proponent shall have to obtain permission from the Airport Authority of India for the proposed height (i.e. 43.3 m) of the buildings. The height of all the / structures shall be restricted to the height as permitted by the Airport Authority of India.

A.1 CONSTRUCTION PHASE: 3. All required sanitary and hygienic measures shall be provided before starting the construction activities and to

be maintained throughout the construction phase. 4. No ground water shall be tapped during the construction phase. 450 KLD water requirement the construction

purpose shall be met through tankers. 5. The construction site shall be provided with barricades of adequate height on its periphery with adequate

signage. 6. Water sprinkling shall be done in vulnerable areas for controlling fugitive emission. 7. Material shall be covered during transportation to avoid the fugitive emission. 8. The roads inside the project area and roads connected to the main road shall be paved or shall be water

sprinkled to avoid the fugitive emissions during construction. 9. Adequate drinking water and sanitary facilities, electricity and ventilation, creches, canteen, rest rooms, safe

disposal system for waste garbage and drainage water, first aid, medical and emergency facilities shall be provided for construction workers to ensure that they do no ruin the existing environmental condition.

10. The project proponent shall provide accommodation to construction workers in labour colony as proposed by them. Provision should be made for the supply of fuel (kerosene or cooking gas), utensils such as pressure cookers etc. to the labours during construction phase.

11. Adequate personal protective equipments shall be provided to the construction workers to ensure their safety and the project proponent shall ensure its usage by the labours.

12. All topsoil excavated during construction activities should be stored separately for use in horticultural / landscape development within the project site.

13. Disposal of debris including the excavated material during construction phase shall not create adverse effect on neighboring communities and disposed off taking the precautions for general safety and health aspects only at the approved sites with the approval of the competent authority.

14. Use of diesel generator sets during construction phase should be enclosed type and conforming to the EPA Rules for air and noise emission standards.

15. Vehicles hired for bringing construction material at site should be in good conditions and conform to applicable air and noise emission standards and should be operated only during non-peak hours.

16. Ambient noise levels should confirm to residential standards both during day and night. Incremental pollution load on the ambient air and noise quality should be closely monitored during construction phase.

17. Ready made mix concrete should be used so far as possible. 18. Water demand during construction should be reduced by use of curing agents, plasticizers and other best

practices. 19. Fly ash should be used as building material in the construction as per provisions of Fly Ash Notification under

EPA. 20. Structural design aspects in accordance to the seismic zone shall be strictly adhered to. 21. The construction materials and debris shall be properly stored and handled to avoid negative impacts such as

air pollution and public nuisances by blocking the roads and public passages. 22. Use of glass shall be minimal and only low emissive glass with double glazed system will be used in the

project to reduce the electricity consumption and load on air conditioning. 23. Various energy conservation measures shall be implemented viz. use of solar based traffic signals & street

Annex II








lights, sunscreen films on windows to reduce heating inside the buildings, use of energy efficient appliances, use of CFL’s, low voltage lighting, under-deck insulation, minimum window to wall ratio walls on East and West facades, stepped facades to decrease heat transmission from walls as well as maximizing the use of natural lighting through design features, use of energy efficient T5 tubes & PL lamps, use of timers for corridors / carpark lighting, timers & photoelectric sensors for external landscape lighting etc. Means for passive solar cooling utilizing building shading shall be adopted.

24. Environment Management Cell shall be formed, which shall supervise and monitor the environment related aspects of the project during construction and operational phases in addition to observance of Gujarat Building and other Construction Workers Rules.

A.2 OPERATION PHASE: 25. Total (fresh + recycled) water requirement during the operation of first phase shall be 726 KLD, out of which

484 KLD fresh water requirement shall be met through AMC water supply and the remaining 242 KLD water requirement shall be met through treated sewage from the proposed STP. Metering of the water shall be done and its records shall be maintained. No ground water shall be tapped.

26. Low water consuming devices shall be provided. Fixtures for showers, toilet, flushing and drinking shall be of low flow either by use of aerators/ diffusers or pressure reducing devices etc.

27. The sewage generation from the first phase of the project shall not exceed 654 KLD. The sewage shall be treated in modular STP based on SAFF technology. The project proponent shall install and efficiently operate their own sewage treatment plant (STP) so as to achieve the GPCB norms.

28. The treated sewage conforming to the GPCB norms shall be partly reused for flushing (242 KLD) & green belt development (75 KLD) and rest shall be discharged into municipal drain.

29. Dual plumbing system with separate tanks and lines shall be provided for utilization of treated sewage for flushing.

30. Best available technology such as Ultra violet radiation shall be used for disinfection of sewage before reuse / recycle / discharge.

31. Rain water harvesting for roof run-off and surface run-off, as per the details submitted shall be carried out. Before recharging the surface run off, pre-treatment must be done to remove suspended matter.

32. The municipal solid waste (@ 1.88 MT/day) shall be properly collected and segregated at source. The recyclable material shall be sold to proper vendor and other garbage shall be composted with help of organic water converter to make manure.

33. Hazardous wastes i.e. used oil generated from DG set / other machinery overhauling and transformer oil replacement shall be sold off to the registered recyclers and any other type of hazardous waste generating from the project if any, shall be disposed as per the Hazardous Waste (Management, Handling and Transboundary Movement) Rules 2008, as may be amended from time to time.

34. The stack height of the DG Sets shall be equal to the height needed for the combined capacity of all proposed DG sets. The gaseous emissions from the D. G. Sets shall conform to the standards prescribed by GPCB. At no time, the emission levels shall go beyond the stipulated standards.

35. The greenbelt shall be developed over the area of 1,25,856.3 sq.m. by growing at least 5450 trees of local species, as per the plan submitted. The open spaces inside the plot shall be suitably landscaped and covered with vegetation of indigenous variety. The area earmarked as green area shall be used only for greenbelt and shall not be altered for any other purpose.

36. The project proponent shall install the electric utilities / devises, which are energy efficient and meeting with the Bureau of Energy Efficiency norms, wherever applicable. Energy Conservation Building Code [ECBC] norms shall be implemented in the project.

37. The energy audit shall be conducted at regular interval for the project and the recommendations of the Audit Report shall be implemented with spirit.

38. The acoustic enclosures shall be installed at all noise generating equipments such as DG sets, air conditioning systems, etc. and the noise level shall be maintained as per the MoEF / CPCB guidelines / norms both during day and night time.

Annex II








39. Parking space of at least 1740 ECS shall be provided for the parking purpose, as proposed. The area earmarked for the parking shall be used for parking only. No other activity shall be permitted in this area.

40. No public space shall be used or blocked for the parking and the trained staff shall be deployed to guide the visitors for parking and helping the senior citizens and physically challenged people.

41. Traffic congestion near the entry and exit points from the roads adjoining the proposed project site must be avoided.

42. The project management shall prepare a detailed Disaster Management Plan (DMP) for the operational phase of the project.

43. Necessary emergency lighting system alongwith emergency power back up system shall be provided. In addition, emergency siren/public address system arrangement shall be provided in the township.

44. Necessary signage/maps at all appropriate places shall be provided to guide the people towards exits and assembly points during the unforeseen emergency and untoward conditions.

45. Compulsory Training to the staff for the first aid and fire fighting along with regular mock drill shall be made an integral part of the emergency management plan of the project.

46. All the statutory clearances such as the approvals for storage of diesel from Chief controller of Explosives, Fire Department, if applicable, shall be obtained as applicable by the project proponents from the competent authorities.

47. Environment Management Cell shall be formed during operation phase which will supervise and monitor the environment related aspects of the project including performance of the Sewage Treatment Plant, incremental pollution loads on the ambient air quality, noise and water quality periodically.

48. All the staircases and lifts shall open out at ground level for emergency evacuation. 49. The planning design and construction of all buildings shall be such as to ensure safety from fire. Adequate

fire fighting facilities as proposed shall be provided. 50. Necessary smoke detection systems, comprehensive fire fighting network along with adequate number of fire

extinguishers shall be provided. 51. Adequate margin all round the periphery shall be provided for turning around of the passage of fire

tender/emergency vehicle without reversing. 52. The project proponent shall also comply with any additional conditions that may be imposed by the SEAC or

the SEIAA or any other competent authority for the purpose of the environmental protection and management.

C. GENERAL CONDITIONS: 53. The project proponent shall permit the outside people to use the social infrastructures like hospital, schools,

colleges etc. coming up in the proposed project, as per their undertaking dated 21/07/2009. 54. Various provisions of the Environment (Protection) Act, 1986 and the Rules / Notifications issued thereunder

by the Ministry of Environment and Forests, Government of India, from time to time shall be strictly complied with.

55. No further expansion or modifications in the plant shall be carried out without prior approval of the MoEF/ SEIAA, as the case may be. In case of deviations or alterations in the project proposal from those submitted to MoEF/ SEIAA/ SEAC for clearance, a fresh reference shall be made to the SEIAA/ SEAC to assess the adequacy of conditions imposed and to add additional environmental protection measures required, if any.

56. The project authorities shall earmark adequate funds to implement the conditions stipulated by SEIAA as well as GPCB along with the implementation schedule for all the conditions stipulated herein. The funds so provided shall not be diverted for any other purpose.

57. The applicant shall inform the public that the project has been accorded environmental clearance by the SEIAA and that the copies of the clearance letter are available with the GPCB and may also be seen at the Website of SEIAA/ SEAC/ GPCB. This shall be advertised within seven days from the date of the clearance letter, in at least two local newspapers that are widely circulated in the region, one of which shall be in the Gujarati language and the other in English. A copy each of the same shall be forwarded to the concerned Regional Office of the Ministry.

Annex II








58. It shall be mandatory for the project management to submit half-yearly compliance report in respect of the stipulated prior environmental clearance terms and conditions in hard and soft copies to the regulatory authority concerned, on 1st June and 1st December of each calendar year.

59. The project authorities shall also adhere to the stipulations made by the Gujarat Pollution Control Board. 60. The project authorities shall inform the GPCB, Regional Office of MoEF and SEIAA about the date of financial

closure and final approval of the project by the concerned authorities and the date of start of the project. 61. The SEIAA may revoke or suspend the clearance, if implementation of any of the above conditions is not

found satisfactory. 62. The company in a time bound manner shall implement these conditions. The SEIAA reserves the right to

stipulate additional conditions, if the same is found necessary. The above conditions will be enforced, inter-alia under the provisions of the Water (Prevention & Control of Pollution) Act, 1974, Air (Prevention & Control of Pollution) Act, 1981, the Environment (Protection) Act 1986, Hazardous Wastes (Management and Handling) Rules, 2003 and the Public Liability Insurance Act, 1991 along with their amendments and rules.

63. This environmental clearance is valid for five years from the date of issue. With regards, (R.G.SHAH) Member Secretary Issued to: M/s Godrej Properties Ltd., Survey No. 54/P,44,108,46,43,82,83,92,66/P,29,15/P,33,16, Village : Jagatpur, Ta: Dascroi, Dist: Ahmedabad CCooppyy ttoo::-- 11.. TThhee SSeeccrreettaarryy,, DDeeppaarrttmmeenntt ooff EEnnvviirroonnmmeenntt aanndd FFoorreessttss,, GGoovvtt.. ooff GGuujjaarraatt,, SSeeccrreettaarriiaatt,, GGaannddhhiinnaaggaarr--338822001100.. 22.. TThhee CChhaaiirrmmaann,, CCeennttrraall PPoolllluuttiioonn CCoonnttrrooll BBooaarrdd ,, PPaarriivveesshh BBhhaavvaann,, CCBBDD --ccuumm--OOffffiiccee CCoommpplleexx,, EEaasstt AArrjjuunn NNaaggaarr,, NNeeww DDeellhhii--111100003322 33.. TThhee CChhiieeff CCoonnsseerrvvaattoorr ooff FFoorreessttss ((CCeennttrraall)),, MMiinniissttrryy ooff EEnnvviirroonnmmeenntt && FFoorreessttss,, RReeggiioonnaall OOffffiiccee ((WWZZ)),, EE--55,, AArreerraa CCoolloonnyy,, LLiinnkk RRooaadd--33,, BBhhooppaall--446622001166,, MMPP 44.. MMoonniittoorriinngg CCeellll,, MMiinniissttrryy ooff EEnnvviirroonnmmeenntt aanndd FFoorreessttss,, PPaarryyaavvaarraann BBhhaavvaann,, CCGGOO CCoommpplleexx,, NNeeww DDeellhhii--111100000033.. 55.. TThhee MMeemmbbeerr SSeeccrreettaarryy,, GGuujjaarraatt PPoolllluuttiioonn CCoonnttrrooll BBooaarrdd,, PPaarryyaavvaarraann BBhhaavvaann,, SSeeccttoorr--1100 AA,, GGaannddhhiinnaaggaarr--338822001100 66.. SSeelleecctt FFiillee

(R.G.SHAH) Member Secretary

Annex II






Annex III


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Annex IV


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Annex V


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Annex III Action taken Report on Non

Complied and Partly Complied EC Conditions

Action taken Report of Phase I

Godrej Garden City, Ahmedabad - Phase I Action Plan on Partly Complied and Non Complied issues in the EC Conditions =====================================================================================================================

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Action Plan on Partly Complied and Non Complied Issues in the EC Conditions

PHASE I Sr. No. Conditions Compliance

Specific Conditions Construction Phase

Condition 4 Non Complied

No ground water shall be tapped during the construction phase. 450 KLD water requirements of the construction purpose shall be met through tankers.

Our original submission on 9th November 2017: Water during construction was obtained through private suppliers. No ground water was abstracted either for construction or for labour colony. Water requirement varied depending on the pace and nature of construction activity. Approximately 45 - 60 tankers of 7 - 8 kld capacity were deployed for construction on a daily basis. About 25 to 28 kld of water was used for domestic purposes (in the labour colony) and 350 to 400 kld was used for construction and sprinkling activities. Total water consumption never exceeded 450 kld at the time of construction. Water consumption was optimised in the project by using treated water from the STP for sprinkling activities for dust suppression. Reason stated by MoEF&CC for Non-Compliance on 30th November 2017: Copy of agreement with tanker supplier and total consumption tallying with billed amount needs to be established for its compliance. It is also to be established that the tanker supplier has not sourced ground water and thus defeating the purpose of not using ground water. Action taken for Compliance by Godrej Garden City (being submitted herewith): Water tanker bills from the water supplier are enclosed as Annex I for a month of summer and winter of 2012 to exhibit water utilisation in summer and winter months. It can be noticed that summer month bills (when water consumption is generally high due to high evaporation losses and frequent concrete curing as well as vegetation irrigation requirements) are well within the 450 kld quantity mentioned in the EC letter.

Condition 9 Partly Complied

Adequate drinking water and sanitary facilities, electricity and ventilation, crèches, canteen, rest rooms, safe disposal system for waste garbage and drainage water, first aid, medical and emergency facilities shall be provided for construction workers to ensure that they do not ruin the existing environmental condition.

Our original submission on 9th November 2017: Adequate labour amenities were provide at site by the civil contractors as part of contract condition. Details of labour amenities are given. In addition to domestic amenities, provision for medical care was provided to the labourers by means of well-equipped and manned medical centre at the site and a dedicated ambulance. The project site was not used for agriculture since last few years and was lying barren before initiation of construction. The nearest habitation from the site is village Jagatpur, about 200 m away. There were no trees at site that could be cut by the construction labourers for fuel wood. No other possibility for damage of the site environment by labourers was possible. Reason stated by MoEF&CC for Partial Compliance on 30th November 2017: The photographs are given below. In view of the above submissions, conditions may be considered complied. However, it was noticed during site inspection that septic tank was not provided which could have polluted the ground water.


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Action taken for Compliance by Godrej Garden City (being submitted herewith): The labour colony was erected in the end of 2013. Our 1000 KLD STP was commissioned in the end of 2014. The standalone soak pit in the colony functioned for the intervening period sheer by oversight and lack of supervision on part of the contractor before the temporary toilets were connected to the STP and sewage was treated in the STP in all earnestness. We hereby assure such instances shall strictly not be allowed.

First Aid Centre Health Check up Safety Signage Safety Signage

Drinking Water Facility Toilets for Labours Crèche Area Tool box Meeting


Ambient noise levels should confirm to residential standards both during day and night. Incremental pollution load on the ambient air and noise quality should be closely monitored during construction phase.

Our original submission on 9th November 2017: Ambient Air and Noise quality is monitored once in six months as a part of EC compliance. Analysis results was submitted with earlier reply. The results indicate that the values conform to the residential standards prescribed by GPCB in their CtE (CTE no. – 48942) of 12th September, 2012. The trend in AAQ in terms of SO2, NOx and PM levels is given in following Table.

Sr.no. Parameter Results (in µg/m3)

NAAQS standards (in µg/m3)

1 PM10 51.93 100


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2 PM2.5 15.14 60 3 SO2 11.28 80 4 NO2 9.66 80

Reason stated for Partial Compliance by MoEF&CC on 30th November 2017: In view of the submissions, condition may be considered partly complied. The PP needs to furnish summary of noise level analysed data to show non-violation. Action taken for Compliance by Godrej Garden City (being submitted herewith): Summary of Noise and Air quality analysis conducted six-monthly since 2015 is enclosed as Annex II to this Report.


Use of glass shall be minimal and only low emissive glass with double glazed system will be used in the project to reduce the electricity consumption and load on air conditioning.

Our original submission on 9th November 2017: Only residential buildings were constructed in Phase I. Glass were used only in fenestrations which was less than 15% of the total wall area. No elaborate, decorative glass façade was involved in any of the buildings. As declared in the Green Building Certification submissions, low emissive glass was used for windows. The specification of glass used is as follows.

Glass thickness: 6 mm clear glass Glass type/Model No.: 6 mm clear glass/ Saint Gobain ST 167 Fenestration U-Factor: 5.7 W/ Sq.m. K Fenestration SHGC-all: 0.67 Fenestration Visible Light Transmittance: 67%

Reason stated for Partial Compliance by MoEF&CC on 30th November 2017: In view of the above submissions, Condition may be considered partially complied. Action taken for Compliance by Godrej Garden City (being submitted herewith): We are not able to follow as to why the condition has been stated as ‘partially complied’. We most humbly resubmit our statement in response to the compliance condition for review.


Various energy conservation measures shall be implemented viz. use of solar based traffic signals & street lights, sunscreen films on windows to reduce heating inside the buildings, use of energy efficient appliances, use of CFL’s, low voltage lighting, under-deck insulation, minimum window to wall ratio walls on East and West

Our original submission on 9th November 2017: Following energy saving measures are incorporated in the project All common passage, estate area illumination on energy saving luminaries/fixtures T5 tubes with electronic ballasts in utility rooms, club house, no use of HPMV or HPSV lamps Estate area illumination partially on solar PV based CFLs Regular de-dusting of the luminaries All Club house ACs have minimum 4-star rating EE drives in elevators, pumps, STP


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facades, stepped facades to decrease heat transmission from walls as well as maximizing the use of natural lighting through design features, use of energy efficient T5 tubes & PL lamps, use of timers for corridors / car park lighting, timers & photoelectric sensors for external landscape lighting etc. Means for passive solar cooling utilizing building shading shall be adopted.

Reason stated for Partial Compliance by MoEF&CC on 30th November 2017: In view of the above submissions, condition may be considered partially complied. Action taken for Compliance by Godrej Garden City (being submitted herewith):

a. The Project has been designed based on principles of passive architecture for better natural day light illumination, cumulative shading, etc. by sun path analysis and modelling.

b. ECBC Guideline, 2007 has been thoroughly followed in design of the building interiors, electrical and HVAC/passive ventilation system so as to ensure minimum energy utilization and minimum wastage of power for illumination, cooling and ventilation of the building common areas as well as dwelling units.

c. Energy performance of the buildings are periodically assessed by means of conducting energy audits. ECBC Compliance Analysis Reports carried out for the Project (May, 2018) are enclosed as Annex III. The Report comprehensively discuses climate analysis, passive architecture strategies followed and further to be followed, heat island effect, roof glazing and shading, ventilation analysis, etc.

d. The ECBC Compliance Analysis Reports carried out for the residential, commercial and school state that the energy performance of the buildings are better than the ECBC, 2007 base case, confirming that the energy efficiency measures (both active and passive) are effectively contributing to the objective of energy efficiency and optimal consumption as meant in the Environmental Clearance.


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Use of Solar Energy for Street Lighting


Environment Management Cell shall be formed, which shall supervise and monitor the environment related aspects of the project during construction and operational phases in addition to observance of Gujarat Building and other Construction Workers Rules.

Our original submission on 9th November 2017: Environment and safety Management Cell was formed by the civil contractors specific to the project. A dedicated project supervision team of GPL was responsible for ensuring fulfilment of EHS measures by the civil contractor. SOPs were agreed upon and followed for the EHS component of construction. Documentation on non-compliance of EHS measures was carried out on a daily basis and the NCs were closed/matters were resolved before initiation of construction. A monthly MIS was submitted by the civil contractors which carried indices for safety and environmental measures undertaken at the site. Adherence to the agreed upon EHS performance was an essential condition in clearance of running bills of the civil contractors. Rules and Orders made by the Labour and Employment Department of GoG by their Notification dated 18th August, 2003; Gujarat Building and other Construction Workers Rules were followed by the Civil Contractors in every aspect wherever applicable. Outline of the EM Cell at the site during construction phase was given in earlier reply. Reason stated for Partial Compliance by MoEF&CC on 30th November 2017:


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The PP need to recruit at least one person from Environment Engineering and one from Environment Science. In view of the above submissions, condition may be considered partially complied. Action taken for Compliance by Godrej Garden City (being submitted herewith): Environment and safety Management Cell was formed by the civil contractors specific to the project. A dedicated project supervision team of GPL was responsible for ensuring fulfilment of EHS measures by the civil contractor. SOPs were agreed upon and followed for the EHS component of construction. Documentation on non-compliance of EHS measures was carried out on a daily basis and the NCs were closed/matters were resolved before initiation of construction. A monthly MIS was submitted by the civil contractors which carried indices for safety and environmental measures undertaken at the site. Adherence to the agreed upon EHS performance was an essential condition in clearance of running bills of the civil contractors. Rules and Orders made by the Labour and Employment Department of GoG by their Notification dated 18th August, 2003; Gujarat Building and other Construction Workers Rules were followed by the Civil Contractors in every aspect wherever applicable. We have appointed safety and environment experts to look into EHS related issues of the township during operation phase Outline of the EM Cell during the construction phase and present is given below.


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Operation Phase


Total (fresh + recycled) water requirement during the operation of first phase shall be 726 KLD, out of which 484 KLD fresh water requirement shall be met through AMC water supply and the remaining 242 KLD water requirement shall be met through treated sewage from the proposed STP. Metering of the water shall be done and its records shall be maintained. No ground water shall be tapped.

Our original submission on 9th November 2017: The total water demand in Phase I during operation phase is 726 KLD (Fresh water demand of 484 KLD +

242 KLD of treated water from STP (refer given below water balance chart).

Freshwater is being obtained from AMC area through private suppliers using tankers. Infrastructure for receipt of AMC water supply has been constructed by Godrej and the connection from AMC is under implementation (Permission of water supply from AMC was submitted with earlier reply)

Treated and disinfected water to the tune of 242 KLD from the existing STP of 1000 KLD is used for horticulture and sundry sprinklings.

Metering of AMC water at the supply header will be carried out using magnetic flow meter installed and sealed

by AMC. Payment for water supply will be billed by AMC based on the reading of this meter. (Electricity Bills from UGVCL for STP Operations was submitted with earlier reply)


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Reason stated for Non-Compliance by MoEF&CC on 30th November 2017: It may be seen that metering has not been done which was mandated in condition. During site visit use of treated water was not observed though claimed so. In fact one of the STP (of phase V) was found to be totally non-functional and inundated with flood water during inspection. Freshwater is reported to be collected through private tankers and the connection from AMC is under implementation. Thus the condition that 484 kld freshwater is to be met through AMC water supply has not been complied. Action taken for Compliance by Godrej Garden City (as submitted herewith): Water supply to the Township by AMC piped supply is at advanced stage of implementation. Metering of AMC water at the supply header will be carried out using magnetic flow meter installed and sealed by AMC. Payment for water supply will be billed by AMC based on the reading of this meter. Flow meters are installed on the inlet and outlet of all STPs. Out of apprx. 3500 KLD STPs cumulatively cleared in the Environmental Clearances of Phase I, III and V, 1000 KLD, 250 KLD and 100 KLD is consructed and the designing of another 1600 KLD STP is going on. The constrution of STPs are on cluster basis. The figure given in the EC is for a group of buildings out of which some have not come up in Phase V. We have constructed a 250 KLD STP (Phase V) based on MBBR technology for ‘Carmel’ cluster buildings which was not commissioned at the time of site visit. Filter media to be charges in the aeration reactor was stocked in PVC bags in the STP room. Since there were heavy rains three days before the visit, there was rainwater ingress in the below grade installation. Cleaning of the STP has been duly completed and we are trageting putting it to operations soon. It may be noted, however, that the occupied buildings in the Carmel cluster are connected to the exisitng 1000 KLD STP which at present typically experieinces about 60% utilization. Sewage from the Carmel cluster buildings are now distributed between these two STPs to maintain optimal volumetric load in both STPs ofr their satisfactory functioning. Rainwater ingress to the below grade STP installation has been addressed by construction of a margin wall of about one foot around the STP building.


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Water Saving Aerator Flush Tank with Double Cisternae Water Saving Shower


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The sewage generation from the first phase of the project shall not exceed 654 KLD. The sewage shall be treated in modular STP based on SAFF technology. The project proponent shall install and efficiently operate their own sewage treatment plant (STP) so as to achieve the GPCB norms.

Our original submission on 9th November 2017: Sewage from Phase has not exceeded 654 KLD, as mentioned in the Water Balance given in condition no. 25 above). A 654 KLD SAFF Technology based STP was proposed for phase I. Planning for Phase III development was going on at the time of EC process of Phase I. Based on sewage generation forecast of Phase III, it was thought prudent to install a centralised STP based on diffused aeration based ASP of 1000 kld to accommodate sewage from both the phases. The STP has been in continuous and trouble free operation since 2014. It meets GPCB discharge standards as stipulated in the GPCB CCA No. AWH-80446, dated 19th July, 2017. Analysis results of STP outlet is given below.

Parameters June-15 Dec-15 Jun-16 Dec-16 Jun-17

GPCB Std Limit

Units

TSS 7.88 7.63 Nil Nil 34 <30*

mg/l COD 48.00 43 45.89 <10 41 -

BOD 7.39 6.12 7.26 <5 <5 100*

Note: *TSS and BOD limits are as given in CCA. Reason stated for Partial Compliance by MoEF&CC on 30th November 2017: It has been simply mentioned that sewage from phase has not exceeded 654 kld. Exact quantity being generated does not seem to have been measured. Also SAFF based STP was not installed as a centrally planned STP of 1000 kld based on ASP was put in place. This is in violation of mandated condition. Housekeeping of was also poor and needs immediate attention including sludge handling system. While the entire issue may have to be the looked in terms of religious compliance, the condition may be considered partly complied in view of the fact that STP has been set up. Action taken for Compliance by Godrej Garden City (as submitted herewith): Though it was planned to have an individual STP to treat 654 KLD from buildings in Phase I, the proposal was changed as Phase II constructions also started while Phase I was still under construction. Considering the feasibility of a larger single STP for the clusters, 1000 kld was proposed. Flow meters are now installed at the outlet of the 1000 kld STP and the records are regularly maintained.


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Flow meter instated at outlet point Flow meter instated at inlet point

Condition 31

Complied Subject to condition

Rain water from terrace area, paved area, garden area, roads etc. though storm water drain (SWD) shall be diverted to 15 nos. of ponds with recharging structures with tube wells for recharging ground water table. Each pond shall consist of 3 nos. of recharging structures with tube wells of different depths in each recharging structure. Before recharging the surface run off, pre-treatment must be done to remove suspended matter.

Our original submission on 9th November 2017: Roof top rainwater is collected through down take pipes directly leading to the percolation wells constructed at regular intervals along the storm water network. 19 no. of percolation wells have been provided at present. In addition, 36 nos. of rain water collection tanks of total 1620 m3 capacity have also been provided. The grit and organic matter is removed while the water is passed through the gravel and sand layers of the harvesting system. Surface runoff are collected in tank first and then allowed to percolate to the ground water by recharging through recharging structures. Selected photographs of the RWHS implemented in the project are given below. Reason stated for Complied Subject to condition by MoEF&CC on 30th November 2017: The photographs are available in the main report. In view of the above submissions, and the pretreatment being insufficient, may be enhanced suitably. The condition may be considered complied subject to this. Action taken for Compliance by Godrej Garden City (as submitted herewith): The Rain Water Harvesting Structure implemented in the Township uses an AMC prescribed design for collection of storm water from paved surface overflow as well as from building rooftops. It comprises a 40 sq.m, 3.9 m


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deep, below-grade concrete interception chambers laid down in tandem in the below-grade storm water network with sequential invert levels. All the RWH chamber are provided with a concentric pipe design with the 150 mm dia inner MS perforated pipe going up to 90 m, and the 300 mm dia solid outer MS pipe going up to 29 m, thus delivering the rain water very deep into the confined aquifers. The upper end of the pipe is provided with Johnson V wire filter screen to filter out any debris and prevent clogging of the pea gravel packing of the harvesting well. The below-grade interception chambers are also provided with 1:100 slope leading to 750x750x450 (in mm) sump for collection of muck/slush/debris. The RWH chambers including the wire filter screens and sump are cleaned pre-monsoon. As the project does not involve possibility of any chemical contaminants mixing with rain water, simple pre-filtration of the rain water inside the RWH interception chambers is considered adequate pre-treatment."

Rain Water Harvesting Tank under Construction Rain water Harvesting Pits Strom Water Drain connected to Pits


The municipal solid waste (@ 1.88 MT/day) shall be properly collected and segregated at source.

Our original submission on 9th November 217: Door to door collection, segregation and appropriate disposal of garbage is being carried out by AMC at present using their city-wide municipal waste management system. An Organic Waste Convertor (OWC) of 500 kg/day has been procured and has been successfully commissioned recently. Door to door collection of waste using two bin system for at-source segregation, and composting of biodegradable waste equal to the capacity of the OWC has started. Technical details of OWC manufactured by ECOMAN ENVIRO SOLUTIONS PVT. LTD. is enclosed. Non-biodegradable waste segregated by the two bin system as well as at the OWC pre-sorting station is taken away by AMC using their present infrastructure. Reason stated for Partial Compliance by MoEF&CC on 30th November 2017:


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The recyclable material shall be sold to proper vendor and other garbage shall be composted with help of organic waste converter to make manure.

The collection and segregation system of solid waste was not found developed fully. In fact, around the time of visit, the PP was in the process of commissioning the OWC. Also quantification of the waste was not done. Action taken for Compliance by Godrej Garden City (as submitted herewith): Door to door collection of waste using two bin system for at-source segregation, and composting of biodegradable waste equal to the capacity of the OWC has started. Since generation of organic waste was less than 20% during first few years of occupancy in the Township, installation of Organic Waste Convertor (OWC) was purposefully deffered until adequate volume of the started getting generated. As OWC of 500 kg/day has been procured from M/s Ecoman Environmental Solutions Pvt. Ltd., Pune. Non biodegradable waste was seggregated by the two bin system as well as at the OWC pre sorting station is taken away by AMC using their present infrastructure. At present approx. 1000 dwelling units are occupied and an OWC of 500 kg/day is totally functional. The manure generated in a day is used as fertilizer within the township. Dry/inert waste has been disposed off to authorized municipal solid waste disposal site.


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Organic Waste Convertor at site

Collection of Dry & Wet Waste VMC’S Soild Waste Collection Van at site

Condition 33

Hazardous wastes i.e. used oil generated from DG set / other

Our original submission on 9th November 2017:


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Non Compliance till amendment is obtained

machinery overhauling and transformer oil replacement shall be sold off to the registered recyclers and any other type of hazardous waste generating from the project if any, shall be disposed as per the Hazardous Waste (Management, Handling and Trans boundary Movement) Rules 2008, as may be amended from time to time.

Replacement of DG and transformer oils is in the scope of the DG and transformer AMC contractors who have an established and statutorily approved system of onward recovery, reuse and disposal. The Township management ensures the availability and currency of statutory permissions at the time of renewal of the AMC contract. As on now, no used oil has been generated at the site for the following reasons.

a. Power failure at Ahmedabad is close to zero. DG sets are run up few minutes every week to charge the batteries and ensure their working condition.

b. The Township is operational since only 2 years, and change of transformer oil has not been necessary so far.

Reason stated for Non Compliance till amendment is obtained on 30th November 2017: There seems to be production of hazardous in terms of used oil etc. If PP can establish such a claim, PP has to seek suitable amendment in the condition. Till such time it may be considered not complied. Because, the condition “shall be sold off to the registered recyclers and any other type of hazardous waste generating from the project if any, shall be disposed as per the Hazardous Waste (Management , Handling and Trans boundary movement) Rules, 2008, as may be amended from time to time” has not been adhered to. Action taken for Compliance by Godrej Garden City (as submitted herewith): We have a valid Authorization from the GPCB under the Hazardous Waste Rules (No. AWH-80446, dated 15/10/2016), and we are thereunder committed to dispose our hazardous waste following provisions of the Rules as-well-as, as stated in the EC condition. However, we understand that the EC condition is subject to generation of waste. We reiterate that the waste (Used oil from DGs) has not been generated as yes as the DGs have been operated for a very short duration so far.


The stack height of the DG Sets shall be equal to the height needed for the combined capacity of all proposed DG sets. The gaseous emissions from the D. G. Sets shall conform to the standards prescribed by GPCB. At no time, the emission levels shall go beyond the stipulated standards.

Our original submission on 9th November 2017: All DG sets are installed in a distributed manner close to the power feeder busbars of the buildings clusters in open condition. Adherence to GPCB emissions standards has been the primary criteria for selection and procurement of the DGs. DG stack analysis is carried out every month. Performance of a DG set on PM, SO2 and NOx parameters in the last few months of 2017 is given below. Analysis reports of DG emission monitoring are enclosed.

Year 2017 Phase I Parameter SOx (in ppm) NOx (in ppm) PM mg/Nm3

January 39.7 34.3 128.6 February 42.2 44.8 110.3

March 37.2 53.4 101.9 April 35.3 64.72 131.3 May 63.2 42.6 104 June 48.7 52.3 90.6 July 61.8 39.2 134.5


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August 34.1 28.3 120.6 GPCB Permissible

Limit 80 80 150

Reason stated for Partial Compliance by MoEF&CC on on 30th November 2017: Regarding stack height of the DG Sets, neither formula for calculation nor the adopted height has been mentioned. However, the monitored results have been shown to be within GPCB limits. Action taken for Compliance by Godrej Garden City (as submitted herewith): DG sets have been installed in open areas and not at the basements, and are not part of any building. In addition, as the power failure frequency in Ahmedabad is almost nil, DGs are run only for periodic trials. The available formula for stack height calculation of DG sets given in the CPCB Emission Regulation IV is for the DGs which are installed inside a building. The same is not applicable to the DGs as installed in the Township.


The energy audit shall be conducted at regular interval for the project and the recommendations of the Audit Report shall be implemented with spirit.

Our original submission on 9th November 2017: The Energy Performance Study Report carried out for Phase I was submitted with earlier reply. Next audit will be carried out in accordance with the audit schedule. The recommendations will be implemented. Reason stated for complied subject to condition by MoEF&CC on 30th November 2017: The audit has been not conducted regularly. Also the recommendations have not yet been implemented. The PP also need to enumerate the major recommendations emerged out of the audit and submit a definitive timeline for their implementation. Action taken for Compliance by Godrej Garden City (as submitted herewith):

a. Energy performance of the buildings are periodically assessed by means of conducting energy audits. ECBC Compliance Analysis Reports carried out for the Project (May, 2018) are enclosed as Annex III. The Report comprehensively discuses climate analysis, passive architecture strategies followed and further to be followed, heat island effect, roof glazing and shading, ventilation analysis, etc.


c. The ECBC Compliance Analysis Reports carried out for the residential, commercial and school state that the energy performance of the buildings are better than the ECBC, 2007 base case, confirming that the energy efficiency measures (both active and passive) are effectively contributing to the objective of energy efficiency and optimal consumption as meant in the Environmental Clearance.


Traffic congestion near the entry and exit points from the roads adjoining the proposed project site must be avoided.

Our original submission on 9th November 2017: There are ten entry-exist points in the Township as shown in the figure below. The main entry-exist is the one leading to the Jagatpur road further connecting to the Sarkhej Gandhinagar Ring road. At present there is lean traffic on the approach road or from inside the project site. However, a 30m road has been constructed as a central spine of the Township opening on this connecting road. To avoid direct merging


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of traffic on this road, a bell mouthed entrance is designed. Necessary signage/maps at all appropriate places are provided to guide the people towards exits and assembly points during the unforeseen emergency. Reason stated for Partial Compliance by MoEF&CC on 30th November 2017: It appears that the task has not been attended to in a robust professional manner. As a way forward, the PP may appoint a town planning/traffic management consultant for detailed and suggesting a plan for decongestion of the traffic and increase the safety. Action taken for Compliance by Godrej Garden City (as submitted herewith): The traffic analysis and the finalisation of circulation plan was done based on an elaborate study carried out by Engineering & Planning Consultants, Mumbai before finalisation of the Master Plan. The Traffic Report prepared by M/s Engineering & Planning Consultants, Mumbai in 2008 is submitted herewith as Annex IV to this Report in support of due studies having been conducted and its recommendations been followed in laying out roads and associated traffic systems in the township.


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Environment Management Cell shall be formed during operation phase which will supervise and monitor the environment related aspects

Our original submission on 9th November 2017: Environment Management Cell has been formed under the supervision of respective functional area heads. EMC members in a distributed responsibility format supervise day to day functioning of pollution control systems,


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of the project including performance of the Sewage Treatment Plant, incremental pollution loads on the ambient air quality, noise and water quality periodically.

environmental quality at the project site, landscape development, safety issues, environmental monitoring documentation and reporting. The organogram of EMC with respective persons’ names is given.

Reason stated for Partial Compliance by MoEF&CC on 30th November 2017: The PP needs to recruit at least one person from Environment Engineering and one from Environment Science. In view of the above submissions, condition may be considered partially complied. Action taken for Compliance by Godrej Garden City (as submitted herewith): Mr. Dhiraj Kumar, M.Sc Environmental Science is working as Manager Safety. His Job description includes

HSE induction training for Engineers & Workers, Conducting JPSC, Rapid Audits Electrical Safety Committee Walk down, Weekly Safety Walk down with Contractors, Participating in tool-

box talks, PEP talks at work-fronts Conducting onsite training for workers & supervisors Preparing in Monthly Safety Activity/ Calendar Site Safety inspection with Project Manager Implementation Fire Fighting and Emergency Rescue plan at the Project site Inspection of PPE’s Organizing events such as World Environment Day, Safety Day, and Aids Day etc. Organizing motivational programmes Mock drill for workman safety etc.

Mr. Chirag Mewada, Diploma in Civil Engineering with professional qualification of Lead Engineer Manpower and resources. He is involved in

Facilities Management including STP and OWC Management operations involving utilities and infrastructure management and upkeep Housekeeping Security and Safety Fire Fighting Transport Management Contract Management and Management of crisis of various emergencies.


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CVs of experts in environmental management is enclosed as Annex V. The organogram of present EMC with respective persons’ names is given below.


The applicant shall inform the public that the project has been accorded environmental clearance by the SEIAA and that the copies of the clearance letter are available with the GPCB and may also be seen at the Website of SEIAA/ SEAC/ GPCB. This shall be advertised within seven days from the date of the clearance letter, in at least two local newspapers that are widely

Our original submission on 9th November 2017: Public Notice regarding prior Environmental Clearance of Phase I was published in Times of India, Divya Bhaskar, Gujarat Samachar and Sandesh dated 2ndApril, 2012. Copy of the newspaper advertisements is given. Copies of the advertisements were duly submitted to MoEF RO, Bhopal along with the Ist half yearly compliance report. Reason stated for Non-Compliance by MoEF&CC on 30th November 2017: It may be seen that advertisement was published after about one and half years instead of mandated requirement of seven days Action taken for Compliance by Godrej Garden City (as submitted herewith):


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circulated in the region, one of which shall be in the Gujarati language and the other in English. A copy each of the same shall be forwarded to the concerned Regional Office of the Ministry.

Public Notice regarding prior Environmental Clearance was published immediately after the lapse was realized. This non-compliance for the intervening condition may please be condoned.

Public Notice in Divya Bhaskar (Vernacular Daily)

Public Notice in Gujarat Samachar (Vernacular Daily)

Public Notice in Sandesh(Vernacular Daily)

Public Notice in The Times of India(English Daily)

Condition 58 Inconclusive

It shall be mandatory for the project management to submit half-yearly compliance report in respect of the stipulated prior environmental clearance terms and conditions in hard and soft copies to the regulatory authority concerned, on 1st June and 1st December of each calendar year.

Our original submission on 9th November 2017: Compliance reports have been dutifully submitted to RO Bhopal, SEIAA Gujarat, and SEAC Gujarat on a half-yearly frequency periodically 2014. The EC was obtained on 16thDecember, 2010. After obtaining Occupancy Certificates in 2014 for Phase I development, the compliance reports were not sent in accordance with EIA Notification 2006, Section 9(i), line 4 “Validity of Environmental Clearance (EC) states validity is only till ‘completion of all construction operations in case of construction projects (item 8 of the Schedule). Further, condition No. 62 of the EC letter clearly states that “This environmental clearance is valid for five years from the date of issue.” Reason stated for Inconclusive by MoEF&CC on 30th November 2017: In view of the above submission with particular reference that the six monthly compliance report submission have been discontinued w.e.f 2014, as you may be taken on this compliance. Action taken for Compliance by Godrej Garden City (being submitted herewith): As per our understanding, Validity of Environmental Clearance (EC) is only till ‘completion of all construction operations in case of construction projects (item 8 of the Schedule) as mentioned in the EIA Notification, 2006. Based on the observation of the MoEF&CC in the Certified EC Compliance Report, we will now be sending the compliance report for operation phase forthwith.


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The project authorities shall also adhere to the stipulations made by the Gujarat Pollution Control Board.

Our original submission on 9th November 2017: Consent to Establish (CtE) and Consolidated Consent and Authorization (CCA) have been duly obtained under Water Act, 1974, Air Act, 1981, and E (P) Act, 1986 (and Rules there under). Copy of CtE and CCA for existing operations are enclosed. All the conditions given in the CCA have been adhered to. Compliance of CCA conditions are periodically submitted to the GPCB and the same are monitored by them on a regular frequency. Reason stated for Partial Compliance by MoEF&CC on 30th November 2017: The PP should have submitted a detailed compliance report of at least the major conditions of the GPCB given through CtE and CCA Action taken for Compliance by Godrej Garden City (being submitted herewith): Latest CCA compliance is enclosed as Annex VI herewith in compliance of the EC condition.

Condition 60 Complied subject to condition

The project authorities shall inform the GPCB, Regional Office of MoEF and SEIAA about the date of financial closure and final approval of the project by the concerned authorities and the date of start of the project.

Our original submission on 9th November 2017: The project has been executed from internal accruals and no leverage or financing has been sought from financial institutions. Reason stated for complied subject to condition by MoEF&CC on 30th November 2017: In any case the date of start of the project was also not communicated. In view of the about submission, the condition may be considered complied subject to suitable amendment of the condition. Action taken for Compliance by Godrej Garden City (being submitted herewith): We request that since the non-applicability is not a non-compliance, amendment to the EC condition may please not be insisted.


The company in a time bound manner shall implement these conditions. The SEIAA reserves the right to stipulate additional conditions, if the same is found necessary. The above conditions will be enforced, inter- alia under the provisions of the Water (Prevention & Control of Pollution) Act, 1974, Air (Prevention & Control of Pollution) Act, 1981, the Environment (Protection) Act 1986, Hazardous Wastes (Management and Handling) Rules, 2003 and the Public Liability Insurance Act, 1991 along with their amendments and rules.

Our original submission on 9th November 2017: Public Liability Insurance Act, 1991 is not applicable to the project as no hazardous chemicals are stored at the site. Reason stated for complied subject to condition by MoEF&CC on 30th November 2017: It seems that PP should have sought amendment to the condition. As per their own report some used oil is generated in the form of hazardous waste. Therefore, necessary amendment is to be obtained and the condition may be considered complied subject to this amendment. Action taken for Compliance by Godrej Garden City (being submitted herewith): We request that since the non-applicability is not a non-compliance, amendment to the EC condition may please not be insisted.

Action taken Report of Phase III

Godrej Garden City, Ahmedabad - Phase III Action taken Report on Partly Complied and Non Complied EC Conditions =====================================================================================================================

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Action taken Report on Partly Complied and Non Complied EC Conditions

PHASE III

Sr. No. Conditions Compliance Specific Condition Construction Phase

Condition 2

Non Complied

The project proponent shall have to obtain permission from the Airport Authority of India (AAI) and Fire & Emergency services Department of the AMC for the proposed building height (i.e. max. 76.25 m for C type buildings) of the buildings before commencing construction activities. The height of all the buildings / structures shall be restricted to the height as permitted by the Airport Authority of India and Fire & Emergency Services Department of the AMC.

Our original submission on 9th November 2017: The height of the structures built as part of Phase III development is 76.25 m tall (C type buildings G+22 floors). Permission (No Objection Certificate for Height Clearance) from Airport Authority of India for the then proposed development was duly obtained. Details of the AAI permissions was submitted with earlier compliance report. Tower cranes were erected for carrying out construction. Tower cranes were raised in segments as the construction progress upwards. They were about 8 m taller than the highest building for a brief period (for about 8 to 12 weeks) before their demobilisation. The Ahmedabad International Airport is about 17 km away from the site. The Township doesn’t lie in the approach funnel on both ends of the airstrip. Aviation lamps were installed on all the tower cranes. Reason stated for Non Compliance by MoEF&CC on 30th November 2017: It is seen that permission, as mandated from the Airport Authority of India (AAI) and Fire & Emergency services Department of the AMC for the proposed building height, have not been obtained. In case these are not required as per the PP, necessary amendment to this condition ought to have been sought from the Authorities before commencement of work preferably. Therefore, until and unless the condition is suitable amended, this may be considered not complied.

Action taken for Compliance by Godrej Garden City (as submitted herewith): NOC for all the constructed buildings have been obtained from AAI. The copies of the same are enclosed as Annex I.

CONSTRUCTION PHASE Condition 4

Partly Complied

No ground water shall be tapped during the construction phase. 102 KLD water requirement the construction purpose shall be met through tankers / AMC water supply.

Our original submission on 9th November 2017: No ground water was abstracted either for construction or for labour colony. Water during construction was obtained through private suppliers. Water requirement varied depending on the pace and nature of construction activity. Approximately 45 - 60 tankers of 7 - 8 kld capacity were deployed for construction on a daily basis. About 10 to 15 kld of water was used for domestic purposes (in the labour colony) and 50 to 100 kld was used for construction and sprinkling activities. Total water consumption never exceeded 102 kld at the time of construction.


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Water consumption was optimised in the project by using treated water from the STP for sprinkling activities for dust suppression. Payment receipts for water tankers were submitted with earlier submitted compliance report. Reason stated for Partial Compliance by MoEF&CC on 30th November 2017: However, there is no agreement/MOU between the tanker suppliers and the PP and also it is to be established that the tanker suppliers did not source groundwater. This is essential to qualify for full compliance. Action taken for Compliance by Godrej Garden City (as submitted herewith): Water tanker bills from the water supplier are enclosed as Annex II for a month of summer and winter of 2014 to exhibit water utilisation in summer and winter months. It can be noticed that summer month bills (when water consumption is generally high due to high evaporation losses and frequent concrete curing as well as vegetation irrigation requirements) are well within the 102 kld quantity mentioned in the EC letter.

Condition 5

Partly Complied

Sewage generated during the construction phase shall be disposed of through septic tank - soak pit.

Our original submission on 9th November 2017: Sewage generated from the construction phase (mainly from the labour colony) initially was disposed through soak pit. The STP of 1000 KLD became operational by the end of 2014 and thereafter the sewage was sent to STP for treatment. The treated water conforming GPCB land disposal criteria was used for sprinkling activities, flushing and horticulture. Reason stated for Partial Compliance by MoEF&CC on 30th November 2017: However, the fact remains that septic tank was not provided for the treating sewage generated during construction phase implying that groundwater could have been polluted, is soak pit only used. Action taken for Compliance by Godrej Garden City (as submitted herewith): The labour colony was erected in the end of 2013. Our 1000 KLD STP was commissioned in the end of 2014. The standalone soak pit in the colony functioned for the intervening period sheer by oversight and lack of supervision on part of the contractor before the temporary toilets were connected to the STP and sewage was treated in the STP in all earnestness.

We hereby assure such instances shall strictly not be allowed.


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Sock Pit STP

Condition 23

Partly

Complied


Our original submission on 9th November 2017: Environment and safety Management Cell was formed by the civil contractors specific to the project. A dedicated project supervision team of GPL was responsible for ensuring fulfilment of EHS measures by the civil contractor. SOPs were agreed upon and followed for the EHS component of construction. Documentation on non-compliance of EHS measures was carried out on a daily basis and the NCs were closed/matters were resolved before initiation of construction. A monthly MIS was submitted by the civil contractors which carried indices for safety and environmental measures undertaken at the site. Adherence to the agreed upon EHS performance was an essential condition in clearance of running bills of the civil contractors. Rules and Orders made by the Labour and Employment Department of GoG by their Notification dated 18th August, 2003; Gujarat Building and other Construction Workers Rules were followed by the Civil Contractors in every aspect wherever applicable. Outline of the EM Cell at the site during construction phase is given below. Reason stated for Partial Compliance by MoEF&CC on 30th November 2017: The PP needs to recruit personnel one each from environment engineering and environmental science background. Action taken for Compliance by Godrej Garden City (as submitted herewith):


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Environment and safety Management Cell was formed by the civil contractors specific to the project. A dedicated project supervision team of GPL was responsible for ensuring fulfilment of EHS measures by the civil contractor. SOPs were agreed upon and followed for the EHS component of construction. Documentation on non-compliance of EHS measures was carried out on a daily basis and the NCs were closed/matters were resolved before initiation of construction. A monthly MIS was submitted by the civil contractors which carried indices for safety and environmental measures undertaken at the site. Adherence to the agreed upon EHS performance was an essential condition in clearance of running bills of the civil contractors. Rules and Orders made by the Labour and Employment Department of GoG by their Notification dated 18th August, 2003; Gujarat Building and other Construction Workers Rules were followed by the Civil Contractors in every aspect wherever applicable. We have appointed safety and environment experts to look into EHS related issues of the township during operation phase

Outline of the EM Cell during the construction phase and the present one at the site is given below.


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Operation Phase

OPERATION PHASE Condition

24

Non Complied

Total (fresh + recycled) water requirement during operation of the third phase shall be 2419 KLD, out of which 1,210 KLD fresh water requirement shall be met through AMC water supply and the remaining 1209 KLD water requirement shall be met through treated sewage from the proposed STP. Metering of the water shall be done and its records shall be maintained. No ground water shall be tapped.

Our original submission on 9th November 2017: The total water demand in Phase III during operation phase is 2419 KLD (Fresh water demand of 1210 KLD + 1209 KLD of treated water from STP (refer given below water balance chart).

Freshwater is being obtained from AMC area through private suppliers using tankers. Infrastructure for receipt of AMC water supply has been constructed by Godrej and the connection from AMC is under implementation (Water supply NOC letter from AMC was submitted with earlier compliance report). Metering of AMC water at the supply header will be carried out using magnetic flow meter installed and sealed by AMC. Payment for water supply will be billed by AMC based on the reading of this meter.


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No groundwater is tapped.

Reason stated for Non Compliance by MoEF&CC on 30th November 2017: It may be seen that metering has not been done which was mandated in condition. During visit use of treated water was not observed although claimed so. In fact one STP (of phase V) was found to be totally non-functional and inundated with flood water during inspection. Freshwater is reported to be collected through private tankers and the connection from AMC is under implementation. Thus the condition that 1210 kld freshwater is to be made through AMC and 1209 kld from treated sewage water supply has not be complied. Action taken for Compliance by Godrej Garden City (as submitted herewith): Water supply to the Township by AMC piped supply is at advanced stage of implementation. Metering of AMC water at the supply header will be carried out using magnetic flow meter installed and sealed by AMC. Payment for water supply will be billed by AMC based on the reading of this meter. Flow meters are installed on the inlet and outlet of all STPs. Out of apprx. 3500 KLD STPs cumulatively cleared in the Environmental Clearances of Phase I, III and V, 1000 KLD, 250 KLD and 100 KLD is consructed and the designing of another 1600 KLD STP is going on. The constrution of STPs are on cluster basis. The figure given in the EC is for a group of buildings out of which some have not come up in Phase V. We have constructed a 250 KLD STP (Phase V) based on MBBR technology for ‘Carmel’ cluster buildings which was not commissioned at the time of site visit. Filter media to be charges in the aeration reactor


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was stocked in PVC bags in the STP room. Since there were heavy rains three days before the visit, there was rainwater ingress in the below grade installation. Cleaning of the STP has been duly completed and we are trageting putting it to operations soon. It may be noted, however, that the occupied buildings in the Carmel cluster are connected to the exisitng 1000 KLD STP which at present typically experieinces about 60% utilization. Sewage from the Carmel cluster buildings are now distributed between these two STPs to maintain optimal volumetric load in both STPs ofr their satisfactory functioning. Rainwater ingress to the below grade STP installation has been addressed by construction of a margin wall of about one foot around the STP building.

Condition 26

Partly

Complied

The sewage generation from the third phase of the project shall not exceed 1637 KLD. The sewage shall be treated in the onsite sewage treatment plant (STP). The project proponent shall install and efficiently operate the STP so as to achieve the GPCB norms at the outlet.

Our original submission on 9th November 2017: Sewage from Phase has not exceeded 1637 KLD, as mentioned in the Water Balance given in condition no. 25 above). A 654 KLD SAFF Technology based STP was proposed for phase I. Planning for Phase III development was going on at the time of EC process of Phase I. Based on sewage generation forecast of Phase III, it was thought prudent to install a centralised STP based on diffused aeration based ASP of 1000 kld to accommodate sewage from both the phases. The STP has been in continuous and trouble fee operation since 2014. It meets GPCB discharge standards as stipulated in the GPCB CCA No. AWH-80446, dated 19th July, 2017. Analysis results of STP outlet is given below.

Parameters June-15 Dec-15 Jun-16 Dec-16 Jun-17 GPCB Standard Limit Units

TSS 7.88 7.63 Nil Nil 34 <30*

mg/l COD 48.00 43 45.89 <10 41 -

BOD 7.39 6.12 7.26 <5 <5 100*

Note: *TSS and BOD limits are as given in CCA.


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Overhead Tank

Reason stated for Partial Compliance by MoEF&CC on 30th November 2017: It has been simply mentioned that sewage from phase has not exceed 1637 kld. Exact quantity being generated does not seem to have been measured. Also SAFF based STP was not installed and centrally planned STP of 1000 kld based on ASP was putting place. This is in violation of the mandated condition. Housekeeping of was also poor and needs immediate attention including sludge handling system. While the entire issue may have to relooked in terms of original compliance, the condition maybe considered partly complied in view of the fact that STP has been set up. Action taken for Compliance by Godrej Garden City (as submitted herewith): Though it was planned to have an individual STP to treat 654 KLD from buildings in Phase I, the proposal was changed as Phase II constructions also started while Phase I was still under construction. Considering the feasibility of a larger single STP for the clusters, 1000 kld was proposed. Flow meters are now installed at the outlet of the 1000 kld STP and the records are regularly maintained.


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Condition 27

Partly

Complied

The treated sewage conforming to the GPCB norms shall be partly reused in flushing (609 KLD) & AC make-up (600 KLD) and balance shall be utilized in green belt development within the premises.

Our original submission on 9th November 2017: The entire tertiary treated and disinfected water from the STP is used for flushing by means of dual plumbing system and gardening by fixed lines as well as distribution system at present. There is no requirement for disposal of treated water into the AMC drains at the present level of development of Township and occupancy. Reason stated for Partial Compliance by MoEF&CC on 30th November 2017: It may be seen that reply is erroneous without application of mind and therefore of bereft of facts. While condition speaks about AC makeup water, the PP referred for AMC drain which is a pure cut and paste syndrome. Action taken for Compliance by Godrej Garden City (as submitted herewith):


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The township at present has residential building and a small shopping center which houses eateries and departmental stores which have standalone Air Conditioning Units. Therefore, there is no requirement of treated water for cooling at present. The entire treated water is used for flushing and for landscaping at present.

Condition 30

Complied Subject to condition

Rain water from terrace area, paved area, garden area, roads etc. though storm water drain (SWD) shall be diverted to 15 nos. of ponds with recharging structures with tube wells for recharging ground water table. Each pond shall consist of 3 nos. of recharging structures with tube wells of different depths in each recharging structure. Before recharging the surface run off, pre-treatment must be done to remove suspended matter.

Our original submission on 9th November 2017: Roof top rainwater is collected through down take pipes directly leading to the percolation wells constructed at regular intervals along the storm water network. The grit and organic matter is removed while the water is passed through the gravel and sand layers of the harvesting system. Surface runoff are collected in tank first and then allowed to percolate to the ground water by recharging through recharging structures. Design of the rainwater percolation wells have been provided by AMC. 19 no. of percolation wells have been provided at present. In addition, 36 nos. of rain water collection tanks of total 1620 m3 capacity have also been provided. Selected photographs of the RWHS implemented in the project are given below. Reason stated for Complied Subject to condition by MoEF&CC on 30th November 2017: The photographs are available in the main report. In view of the above submissions, and the pretreatment being insufficient, may be enhanced suitably. The condition may be considered complied subject to this. Action taken for Compliance by Godrej Garden City (as submitted herewith): The Rain Water Harvesting Structure implemented in the Township uses an AMC prescribed design for collection of storm water from paved surface overflow as well as from building rooftops. It comprises a 40 sq.m, 3.9 m deep, below-grade concrete interception chambers laid down in tandem in the below-grade storm water network with sequential invert levels.

All the RWH chamber are provided with a concentric pipe design with the 150 mm dia inner MS perforated pipe going up to 90 m, and the 300 mm dia solid outer MS pipe going up to 29 m, thus delivering the rain water very deep into the confined aquifers.

The upper end of the pipe is provided with Johnson V wire filter screen to filter out any debris and prevent clogging of the pea gravel packing of the harvesting well. The below-grade interception chambers are also provided with 1:100 slope leading to 750x750x450 (in mm) sump for collection of muck/slush/debris. The RWH chambers including the wire filter screens and sump are cleaned pre-monsoon.


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As the project does not involve possibility of any chemical contaminants mixing with rain water, simple pre-filtration of the rain water inside the RWH interception chambers is considered adequate pre-treatment."

Rain Water Harvesting Tank under Construction Rain water Harvesting Pits Strom Water Drain connected to Pits

Condition 31

Partly Complied

The municipal solid waste (@ 7.39 MT/day) shall be properly collected and segregated at source. The recyclable materials shall be sold to vendors and biodegradable waste shall be vermin composted to make manure.

Our original submission on 9th November 2017: Door to door collection, segregation and appropriate disposal of garbage is being carried out by AMC at present using their city-wide municipal waste management system. An Organic Waste Convertor (OWC) of 500 kg/day has been procured and has been successfully commissioned recently. Door to door collection of waste using two bin system for at-source segregation, and composting of biodegradable waste equal to the capacity of the OWC has started. Technical details of OWC manufactured by ECOMAN ENVIRO SOLUTIONS PVT. LTD. was submitted as with earlier compliance report. Non-biodegradable waste segregated by the two bin system as well as at the OWC pre-sorting station is taken away by AMC using their present infrastructure. Reason stated for Partial Compliance by MoEF&CC on 30th November 2017: The collection and segregation system of solid waste was not found developed fully. In fact, around the time of the visit, the PP was in process of commissioning the OWC. Also, quantification of the waste was not done. Action taken for Compliance by Godrej Gaden City (as submitted herewith):


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As the occupancy was only 20%, the solid waste management system and installation of OWC was delayed. Door to door collection of waste using two bin system for at-source segregation, and composting of biodegradable waste equal to the capacity of the OWC has started. At present approx. 1000 dwelling units are occupied and the OWC of 500 kg/day is totally functional. The manure is generated in a day which is used as fertilizer. An Organic Waste Convertor (OWC) The non-biodegradable waste has been sold to scrap dealers. Dry/inert waste has been disposed off to authorized municipal solid waste disposal site.


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Organic Waste Convertor at site


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Collection of Dry & Wet Waste VMC’S Soild Waste Collection Van at site

Condition 32 Non complained till amendment is obtained.

Hazardous wastes i.e. used oil generated from DG set/other machinery overhauling and transformer oil replacement shall be sold off to the registered recyclers whereas lead chloride batteries shall be given back to suppliers. Any other type of hazardous waste generating from the project if any, shall be disposed as per the Hazardous Waste (Management, Handling and Trans boundary Movement) Rules 2008, as may be amended from time to time.

Our original submission on 9th November 2017: Replacement of DG and transformer oils is in the scope of the DG and transformer AMC contractors who have an established and statutorily approved system of onward recovery, reuse and disposal. The Township management ensures the availability and currency of statutory permissions at the time of renewal of the AMC contract. As on now, no used oil has been generated at the site for the following reasons.


b. The Township is operational since only 2 years, and change of transformer oil has not been necessary so far.

Reason stated for not complied till amendment is obtained by MoEF&CC on 30th November 2017: However, there seems to be production of hazardous waste in terms of used oil etc.


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If the PP can establish search claim they should seek suitable amendment to the condition. Till such time it may be considered not complied. Because, the condition " shall be sold off to the register recyclers and any other type of hazardous waste generating from the project if any, shall be disposed as per the hazardous waste (Management, Handling and Trans boundary Movement) Rules 2008 as may be amended from time to time." Has not been adhered to. Action taken for Compliance by Godrej Garden City (as submitted herewith): We have a valid Authorization from the GPCB under the Hazardous Waste Rules (No. AWH-80446, dated 15/10/2016) and we are thereunder committed to dispose our hazardous waste following provisions of the Rules as-well-as, as stated in the EC condition. However, we understand that the EC condition is subject to generation of waste. We reiterate that the waste (Used oil from DGs) has not been generated as yes as the DGs have been operated for a very short duration so far.

Condition 33

Partly

Complied

The stack height of the DG Sets shall be equal to the height needed for the combined capacity of all proposed DG sets. The gaseous emissions from the D. G. Sets shall conform to the standards prescribed by GPCB. At no time, the emission levels shall go beyond the stipulated standards.

Our original submission on 9th November 2017: All DG sets are installed in a distributed manner close to the power feeder busbars of the buildings clusters in open condition. Adherence to GPCB emissions standards has been the primary criteria for selection and procurement of the DGs. DG stack analysis is carried out every month. Performance of a DG set on PM, SO2 and NOx parameters in the last few months of 2017 is given below. Analysis reports of DG emission monitoring was submitted with earlier compliance report.

Year 2017 Phase III Parameter SOx (in ppm) NOx (in ppm) PM mg/Nm3

January 30.7 45.2 104.3

February 40.5 39.8 131.7

March 47.5 33 124.7

April 55.1 36.7 126.2

May 43.5 36.6 143.7

June 28.2 32 129.5

July 53.2 44.8 112

August 41.9 39.2 94.3

GPCB Permissible Limit 80 80 150

Reason stated for Partial Compliance by MoEF&CC on 30th November 2017:


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Regarding stack height of DG sets neither formula for calculation nor the adopted hide has been mentioned. However, Monitored results has been shown to be within GPCB limits. Action taken for Compliance by Godrej Garden City (as submitted herewith): DG sets have been installed in open areas and not at the basements, and are not part of any building. In addition, as the power failure frequency in Ahmedabad is almost nil, DGs are run only for periodic trials. The available formula for stack height calculation of DG sets given in the CPCB Emission Regulation IV is for the DGs which are installed inside a building. The same is not applicable to the DGs as installed in the Township.

Condition 38

Partly

Complied


Our original submission on 9th November 2017: The Energy Performance Study Report carried out for Phase III was submitted with earlier compliance report. Next audit will be carried out in accordance with the audit schedule. The recommendations will be implemented. Reason stated for Partial Compliance by MoEF&CC on 30th November 2017: The audit has not been conducted regularly. Also the recommendations have not yet been implemented. The PP also need to enumerate the major recommendations emerge out of the audit and submit a definitive timeline their implementation. Action taken for Compliance by Godrej Garden City (as submitted herewith):

a. Energy performance of the buildings are periodically assessed by means of conducting energy audits. ECBC Compliance Analysis Reports carried out for the Project (May, 2018) are enclosed as Annex III. The Report comprehensively discuses climate analysis, passive architecture strategies followed and further to be followed, heat island effect, roof glazing and shading, ventilation analysis, etc.


c. The ECBC Compliance Analysis Reports carried out for the residential, commercial and school state that the energy performance of the buildings are are better than the ECBC, 2007 base case, confirming that the energy efficiency measures (both active and passive) are effectively contributing to the objective of energy efficiency and optimal consumption as meant in the Environmental Clearance.

Condition 42


Our original submission on 9th November 2017: There are ten entry-exist points in the Township as shown in the figure below. The main entry-exist is the one leading to the Jagatpur road further connecting to the Sarkej Gandhinagar Ring road. At present there is lean traffic on the approach road or from inside the project


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Partly Complied

site. However, a 30m road has been constructed as a central spine of the Township opening on this connecting road. To avoid direct merging of traffic on this road, a bell mouthed entrance is designed. Necessary signage/maps at all appropriate places are provided to guide the people towards exits and assembly points during the unforeseen emergency. Reason stated for Partial Compliance by MoEF&CC on 30th November 2017: It appears that the task has not been attendant to in a robust professional manner. As a way forward, the PP may appoint a town planning/ traffic management consultant for detail and suggesting a plan for decongestion of the traffic and increase the safety. Action taken for Compliance by Godrej Garden City (as submitted herewith): The traffic analysis and the finalisation of circulation plan was done based on an elaborate study carried out by Engineering & Planning Consultants, Mumbai before finalisation of the Master Plan. The Traffic Report prepared by M/s Engineering & Planning Consultants, Mumbai in 2008 is submitted herewith as Annex IV to this Report in support of due studies having been conducted and its recommendations been followed in laying out roads and associated traffic systems in the township.


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Condition 56

Partly

Complied

Environment Management Cell shall be formed during operation phase which will supervise and monitor the environment related aspects of the project including performance of the Sewage Treatment Plant,

Our original submission on 9th November 2017: Environment Management Cell has been formed under the supervision of respective functional area heads. EMC members in a distributed responsibility format supervise day to day functioning of pollution control systems, environmental quality at the project site, landscape development, safety issues,


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incremental pollution loads on the ambient air quality, noise and water quality periodically.

environmental monitoring documentation and reporting. The organogram of EMC with respective persons’ names is given as follows.

Reason stated for Partial Compliance by MoEF&CC on 30th November 2017: The PP needs to recruit personnel one is from environment engineering and environment science background. Action taken for Compliance by Godrej Garden City (as submitted herewith): Mr. Dhiraj Kumar, M.Sc Environmental Science is working as Manager Safety. His Job description includes

HSE induction training for Engineers & Workers, Conducting JPSC, Rapid Audits Electrical Safety Committee Walk down, Weekly Safety Walk down with Contractors,

Participating in tool-box talks, PEP talks at work-fronts Conducting onsite training for workers & supervisors Preparing in Monthly Safety Activity/ Calendar Site Safety inspection with Project Manager Implementation Fire Fighting and Emergency Rescue plan at the Project site Inspection of PPE’s Organizing events such as World Environment Day, Safety Day, and Aids Day etc. Organizing motivational programmes Mock drill for workman safety etc.


Facilities Management including STP and OWC


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Management operations involving utilities and infrastructure management and upkeep Housekeeping Security and Safety Fire Fighting Transport Management Contract Management and Management of crisis of various emergencies.

CVs of experts in environmental management is enclosed as Annex V. The organogram of present EMC with respective persons’ names is given below.


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Adequate amount is budgeted for Environment Management.

Sr. No

EMP Aspect (Operation Phase)

Approx. Actual Capital cost (in lakhs)

2011 2012 2013 2014 2015 2016 2017

1 STP and Grey Water Recycling 443.77 4.93 152.19 169.10 23.14 28.42 65.99 -

2 Greenbelt and other landscape development 121.71 9.74 8.52 14.61 18.26 36.51 34.08 -

3 Storm water drain and Rainwater Harvesting System 644.06 - 128.81 128.81 128.81 128.81 128.81 -

4 Solid Waste Management 12.60 - - - - - - 12.6 5 Energy conservation 32.55 - - - 32.55 - - - 6 LEED certification 4.43 - - - - 2.51 1.92 -

Total 1,259.12 14.67 289.52 312.52 202.76 196.26 230.80 12.6

Condition 57

Complied subject to condition

All the statutory clearances such as the approvals for storage of diesel from PESO, Fire & Emergency Services Department, Airports Authority of India, if applicable, shall be obtained as applicable by the project proponents from the competent authorities.

Our original submission on 9th November 2017: Approval for storage of diesel from Chief Controller of Explosives is not applicable to the project as there is no individual bulk storage of HSD (greater than 1000 KL) at site. Certificate in respect of adequate and effective installation of fire safety measures in high rise building with fire prevention and protection system is obtained from AMC‘s Fire and Emergency Services Department for all the building which is a mandatory procedure before obtaining Occupancy Certificate. Reason stated for Complied subject to condition by MoEF&CC on 30th November 2017: In view of the above submissions, condition may be considered complied subject to the condition that approval for storage and diesel from PESO is dropped by the competent authority. Action taken for Compliance by Godrej Garden City (as submitted herewith): Approval from PESO is not required for the project as there is no bulk storage (more than 1000KL) of diesel at the site at any time.

Condition 60


The project management shall also comply with all the environment protection measures, risk mitigation measures and safeguards proposed by them.

Our original submission on 9th November 2017: Compliance of EMP and RA and DMP have been carried out as evidenced in the compliance report and other documents was submitted with earlier compliance report. Reason stated for Complied subject to condition by MoEF&CC on 30th November 2017: It has been seen that Annex XVI comprises of DMP while the detail of EMP are at serial number 63 below. However, details of risk assessment have to be provided. Action taken for Compliance by Godrej Garden City (as submitted herewith): Risk Assessment was submitted as Annexure to the main report. The same is enclosed as Annex VI.


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Condition 64

Partly

Complied

The applicant shall inform the public that the project has been accorded environmental clearance by the SEIAA and that the copies of the clearance letter are available with the GPCB and may also be seen at the Website of SEIAA/ SEAC/ GPCB. This shall be advertised within seven days from the date of the clearance letter, in at least two local newspapers that are widely circulated in the region, one of which shall be in the Gujarati language and the other in English. A copy each of the same shall be forwarded to the concerned Regional Office of the Ministry.

Our original submission on 9th November 2017: Public Notice regarding prior Environmental Clearance of Phase III was published in Times of India, Divya Bhaskar and Gujarat Samachar dated 19th February, 2013. Copy of the newspaper advertisements is given below. Copies of the advertisements were duly submitted to MoEF RO, Bhopal along with the Ist half yearly compliance report. Reason stated for Partial Compliance by MoEF&CC on 30th November 2017: It may be seen that PP has published the advertisement after about 3 and a half months from the date of issue of the letter. Since it was not within 7 days, AC table view for full compliance may be taken. Action taken for Compliance by Godrej Garden City (as submitted herewith): Public Notice regarding prior Environmental Clearance was published immediately after the lapse was realized. This non-compliance for the intervening condition may please be condoned.

Public Notice in Times of India Public Notice in Divya Bhaskar Public Notice in Gujarat Samachar

Condition 65



Our original submission on 9th November 2017: Compliance reports have been dutifully submitted to RO Bhopal, SEIAA Gujarat, and SEAC Gujarat on a half-yearly frequency periodically 2013. Reason stated for Complied subject to condition by MoEF&CC on 30th November 2017: In view of the above submissions, condition may be considered complied. However, copy of last two forwarding letters in support may be provided. Action taken for Compliance by Godrej Garden City (as submitted herewith): Compliance reports have been regularly submitted to RO Bhopal, SEIAA Gujarat, and SEAC Gujarat on a half-yearly frequency periodically 2013. Last two forwarding letters are enclosed as Annex VII.


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Condition 66

Partly

Complied


Our original submission on 9th November 2017: Consent to Establish (CtE) and Consolidated Consent and Authorization (CCA) have been duly obtained under Water Act, 1974, Air Act, 1981, and E (P) Act, 1986 (and Rules there under). Copy of CtE and CCA for existing operations are enclosed. All the conditions given in the CCA have been adhered to. Compliance of CCA conditions are periodically submitted to the GPCB and the same are monitored by them on a regular frequency. Reason stated for Partial Compliance by MoEF&CC on 30th November 2017: The PP should have submitted a detailed compliance report of at least the major conditions of the GPCB given through CtE and CCA. Action taken for Compliance by Godrej Garden City (as submitted herewith): Latest CCA compliance is enclosed as Annex VIII herewith in compliance of the EC condition.

Condition 67


The project authorities shall inform the GPCB, Regional Office of MoEF and SEIAA about the date of financial closure and final approval of the project by the concerned authorities and the date of start of the project.

Our original submission on 9th November 2017: The project has been executed from internal accruals and no leverage or financing has been sought from financial institutions. Reason stated for Complied subject to condition by MoEF&CC on 30th November 2017: In any case the date of start of the project was also not communicated. In view of the above submission, the condition may be considered complied subjective suitable amendment of the condition. Action taken for Compliance by Godrej Garden City (as submitted herewith): We request that since the non-applicability is not a non-compliance, amendment to the EC condition may please not be insisted.


The company in a time bound manner shall implement these conditions. The SEIAA reserves the right to stipulate additional conditions, if the same is found necessary. The above conditions will be enforced, inter-alia under the provisions of the Water (Prevention & Control of Pollution) Act, 1974, Air (Prevention & Control of Pollution) Act, 1981, the Environment (Protection) Act 1986 and Hazardous Wastes (Management Handling and Trans boundary) Rules, 2008 along with their amendments and rules.

Our original submission on 9th November 2017: The condition is noted, accepted and acknowledged. Public Liability Insurance Act, 1991 is not applicable to the project as no hazardous chemicals are stored at the site. Reason stated for Complied subject to condition by MoEF&CC on 30th November 2017: It seems that PP should have sought amendment to the condition. As per their own report, some used oil is generated in form of hazardous waste. Therefore, necessary amendment is to be obtained and the condition may be considered complied subject to this amendment. Action taken for Compliance by Godrej Garden City (as submitted herewith): We request that since the non-applicability is not a non-compliance, amendment to the EC condition may please not be insisted.

Action taken Report of Phase V

Godrej Garden City, Ahmedabad - Phase V Action taken Report on Partly Complied and Non Complied EC Conditions =====================================================================================================================

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Action taken Report on Partly Complied and Non Complied EC Conditions

PHASE V Sr. No. Conditions Compliance

Specific Conditions Construction Phase

Condition 3

Partly Complied

No ground water shall be tapped during the construction phase. 213.50 KLD water requirement the construction purpose shall be met through tankers/ AMC water supply.

Our original submission on 9th November 2017: Water during construction was obtained through private suppliers. No ground water was abstracted either for construction or for labour colony. Water requirement varied depending on the pace and nature of construction activity. Approximately 30 - 40 tankers of 7 - 8 kld capacity were deployed for construction on a daily basis. About 15 to 18 kld of water was used for domestic purposes (in the labour colony) and 170 to 200 kld was used for construction and sprinkling activities. Total water consumption never exceeded 213.5 kld at the time of construction. Water consumption was optimized in the project by using treated water from the STP for sprinkling activities for dust suppression. Payment receipts for water tankers was submitted with earlier compliance report. Reason stated by MoEF &CC for Partial Compliance on 30th November 2017: However, there is no agreement/m o u between the tanker suppliers and the PP and also it is to be established that the tanker suppliers did not source groundwater. This is essential to qualify for full compliance Action taken for Compliance by Godrej Garden City (as submitted herewith): Water tanker bills from the water supplier are enclosed as Annex I for a month of summer and winter of 2015 to exhibit water utilisation in summer and winter months. It can be noticed that summer month bills (when water consumption is generally high due to high evaporation losses and frequent concrete curing as well as vegetation irrigation requirements) are well within the 213.50 kld quantity mentioned in the EC letter.


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Water Sprinkling Activity Filling of Recycle water from STP for Construction Activity

Condition 4

Partly Complied

Sewage generated during the construction phase shall be disposed off through septic tank - soak pit.

Our original submission on 9th November 2017: Simplex labour colony was erected in the end of 2013. Our 1000 KLD STP was commissioned in the end of 2014. The standalone soak pit in the colony functioned for the intervening period sheer by oversight and lack of supervision on part of the contractor before the temporary toilets were connected to the STP and sewage was treated in the STP in all earnestness. We hereby assure such instances shall strictly not be allowed in the future. Corrective actions were taken and the EC condition has been complied after end of 2014. Reason stated by MoEF&CC for Partial Compliance on 30th November 2017: However, the fact remains that septic tank was not provided for the treating sewage generated during construction phase implying that groundwater could have been polluted, is soak pit only used. Action taken for Compliance by Godrej Garden City (as submitted herewith): The labour colony was erected in the end of 2013. Our 1000 KLD STP was commissioned in the end of 2014. The standalone soak pit in the colony functioned for the intervening period sheer by oversight and lack of supervision on part of the contractor before the temporary toilets were connected to the STP and sewage was treated in the STP in all earnestness. We hereby assure such instances shall strictly not be allowed.


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Condition 22

Partly

Complied


Our original submission on 9th November 2017: Environment and safety Management Cell was formed by the civil contractors specific to the project. A dedicated project supervision team of GPL was responsible for ensuring fulfilment of EHS measures by the civil contractor. SOPs were agreed upon and followed for the EHS component of construction. Documentation on non-compliance of EHS measures was carried out on a daily basis and the NCs were closed/matters were resolved before initiation of construction. A monthly MIS was submitted by the civil contractors which carried indices for safety and environmental measures undertaken at the site. Adherence to the agreed upon EHS performance was an essential condition in clearance of running bills of the civil contractors. Rules and Orders made by the Labour and Employment Department of GoG by their Notification dated 18th August, 2003; Gujarat Building and other Construction Workers Rules were followed by the Civil Contractors in every aspect wherever applicable. Reason stated by MoEF&CC for Partial Compliance on 30th November 2017: The people needs to recruit personnel one each from environment engineering and environmental science background. Action taken for Compliance by Godrej Garden City (as submitted herewith): Environment and safety Management Cell was formed by the civil contractors specific to the project. A dedicated project supervision team of GPL was responsible for ensuring fulfilment of EHS measures by the civil contractor. SOPs were agreed upon and followed for the EHS component of construction. Documentation on non-compliance of EHS measures was carried out on a daily basis and the NCs were closed/matters were resolved before initiation of construction. A monthly MIS was submitted by the civil contractors which carried indices for safety and environmental measures undertaken at the site. Adherence to the agreed upon EHS performance was an essential condition in clearance of running bills of the civil contractors. Rules and Orders made by the Labour and Employment Department of GoG by their Notification dated 18th August, 2003; Gujarat Building and other Construction Workers Rules were followed by the Civil Contractors in every aspect wherever applicable. Outline of the EM Cell at the site during construction phase is given below.


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Operation Phase


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OPERATION PHASE

Condition 23

Non Complied

Total (fresh + recycled) water requirement during operation of the third phase shall be 3057 KLD, out of which 1397 KLD fresh water requirement shall be met through AMC water supply and the remaining 1660 KLD water requirement shall be met through treated sewage from the proposed STP.

Metering of the water shall be done and its records shall be maintained. No ground water shall be tapped.

Our original submission on 9th November 2017: The total water demand in Phase V during operation phase did not exceed 3057 KLD as 38% of built up proposed were constructed.

Freshwater is being obtained from AMC area through private suppliers using tankers.

Infrastructure for receipt of AMC water supply has been constructed by Godrej. (NOC letter from AMC was submitted with earlier compliance report).

Treated and disinfected water from the existing STP of 1000 KLD, and proposed STPs (Cluster wise) will be used for flushing, horticulture and sundry sprinklings.


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Metering of AMC water at the supply header will be carried out using magnetic flow meter installed and sealed by AMC. Payment for water supply will be billed by AMC based on the reading of this meter.

Reason stated by MoEF&CC for Non Compliance on 30th November 2017: It may be seen that metering has not been done which was mandated in condition. During visit use of treated water was not observed although claimed so. In fact one STP (of phase V) was found to be totally non-functional and inundated with flood water during inspection. Freshwater is reported to be collected through private tankers and the connection from AMC is under implementation. Thus the condition that 1397 kld freshwater is to be made through AMC and 1660 kld from treated sewage water supply has not be complied. Action taken for Compliance by Godrej Garden City (as submitted herewith): Water supply to the Township by AMC piped supply is at advanced stage of implementation. Metering of AMC water at the supply header will be carried out using magnetic flow meter installed and sealed by AMC. Payment for water supply will be billed by AMC based on the reading of this meter. Flow meters are installed on the inlet and outlet of all STPs. Out of apprx. 3500 KLD STPs cumulatively cleared in the Environmental Clearances of Phase I, III and V, 1000 KLD, 250 KLD and 100 KLD is consructed and the designing of another 1600 KLD STP is going on. The constrution of STPs are on cluster basis. The figure given in the EC is for a group of buildings out of which some have not come up in Phase V. We have constructed a 250 KLD STP (Phase V) based on MBBR technology for ‘Carmel’ cluster buildings which was not commissioned at the time of site visit. Filter media to be charges in the aeration reactor was stocked in PVC bags in the STP room. Since there were heavy rains three days before the visit, there was rainwater ingress in the below grade installation. Cleaning of the STP has been duly completed and we are trageting putting it to operations soon. It may be noted, however, that the occupied buildings in the Carmel cluster are connected to the exisitng 1000 KLD STP which at present typically experieinces about 60% utilization. Sewage from the Carmel cluster buildings are now distributed between these two STPs to maintain optimal volumetric load in both STPs ofr their satisfactory functioning. Rainwater ingress to the below grade STP installation has been addressed by construction of a margin wall of about one foot around the STP building.


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Water Balance chart during operation phase

Condition 25

Partly Complied

The sewage generation from the third phase of the project shall not exceed 1710 KLD. The sewage shall be treated in the onsite sewage treatment plant (STP).

The project proponent shall install and efficiently operate the STP so as to achieve the GPCB norms at the outlet.

Our original submission on 9th November 2017: Sewage from Phase V shall not exceeded 1710 KLD, as mentioned in the Water Balance given in condition no. 23 above. The sewage will be treated in the 1000 kld STP. STPs are proposed to be constructed in a distributed manner, in phases, as-and-when the occupancies are likely to outstrip the capacities of existing STP. The existing 1000 KLD STP is the first of such STPs, which has a capacity utilization of 60% at present. Another STP of 1600 KLD is proposed which will be brought under stream after occupancies of the under-completion Phase V development are realised. The comparative statement of STP performance in terms of key parameters are as follows:


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Parameters June-15

Dec-15

Jun-16

Dec-16

Jun-17

Dec- 17

GPCB Std Limit

Units

TSS 7.88 7.63 Nil Nil 34 0.7 <30*

mg/l COD 48.0 43 45.89 <10 41 48 -

BOD 7.39 6.12 7.26 <5 <5 15 <20* Note: *TSS and BOD limits are as given in CCA.

Reason stated by MoEF&CC for Partial Compliance on 30th November 2017: Exact quantity being generated does not seem to have been measured. Also SAFF based STP was not installed and centrally planned STP of 1000 kld based on ASP was putting place. This is in violation of the mandated condition. Housekeeping of was also poor and needs immediate attention including sludge handling system. While the entire issue may have to relooked. In terms of original compliance, the condition maybe considered partly complied in view of the fact the health STP has been set up. It has been simply mentioned that sewage from phase has not exceed 1710 kld. Exact quantity being generated does not seem to have been measured. Also SAFF based STP was not installed and centrally planned STP of 1000 kld based on ASP was put in place. They will now propose another STP of 1600 KLD but seems only at thought stage. This is in violation of the mandated condition. Housekeeping was also poor and needs immediate attention including sludge handling system. While the entire issue may have to relooked. In terms of original compliance, the condition maybe considered partly complied in view of the fact the health STP has been set up. Action taken for Compliance by Godrej Garden City (as submitted herewith): Though it was planned to have an individual STP to treat 654 KLD from buildings in Phase I, the proposal was changed as Phase II constructions also started while Phase I was still under construction. Considering the feasibility of a larger single STP for the clusters, 1000 kld was proposed. Flow meters are now installed at the outlet of the 1000 kld STP and the records are regularly maintained.


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Condition 26

Partly Complied

The treated sewage conforming to the GPCB norms shall be partly reused in flushing (500 KLD), car wash (92 KLD) & horticulture purpose (1068 KLD).

Our original submission on 9th November 2017: Treated water from STPs is used for flushing, car wash, and horticulture purpose. Reason stated by MoEF&CC for Partial Compliance on 30th November 2017: Nothing mentioned about car washing and horticulture as mandated in condition. Action taken for Compliance by Godrej Garden City (as submitted herewith): Treated water from all the three existing STPs are used for horticulture, flushing and car wash at present. The photographs are given below.


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Dual Plumbing Line Treated Water for washing

Condition 30

Partly Complied

The municipal solid waste (5993 kg/day) shall be properly collected and segregated at source.

The recyclable materials shall be sold to vendors and biodegradable waste shall be converted to manure with help of on-site Organic Waste Convertor.

Our original submission on 9th November 2017: An Organic Waste Convertor (OWC) of 500 kg/day has been procured and has been successfully commissioned recently. Door to door collection of waste using two bin system will be carried out for at-source segregation, and composting of biodegradable waste equal to the capacity of the OWC. Technical details of OWC manufactured by ECOMAN ENVIRO SOLUTIONS PVT. LTD. was submitted with earlier Compliance Report. Non-biodegradable waste segregated by the two bin system as well as at the OWC pre-sorting station will be taken away by AMC using their present infrastructure. Reason stated by MoEF&CC for Partial Compliance on 30th November 2017: The collection and segregation system of solid waste was not found developed fully. In fact, around the time of the visit, the PP was in process of commissioning the OWC. Also, quantification of the waste was not done.


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Action taken for Compliance by Godrej Garden City (as submitted herewith): As the occupancy was only 20%, the solid waste management system and installation of OWC was delayed. Door to door collection of waste using two bin system for at-source segregation, and composting of biodegradable waste equal to the capacity of the OWC has started. At present approx. 1000 dwelling units are occupied and the degradable waste generated is treated OWC of 500 kg/day. The manure is generated in a day which is used as fertilizer. An Organic Waste Convertor (OWC) The non-biodegradable waste has been sold to scrap dealers. Dry/inert waste has been disposed off to authorized municipal solid waste disposal site.


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Organic Waste Convertor


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Collection of Dry and Wet Waste VMC’s Solid Waste Collection Van at Site

Condition 31

Non Complied till amendment is obtained

Hazardous wastes i.e. used oil generated from DG set/other machinery overhauling and transformer oil replacement shall be sold off to the registered recyclers whereas lead chloride batteries shall be given back to suppliers. Any other type of hazardous waste generating from the project if any, shall be disposed as per the Hazardous Waste (Management, Handling and Tran’s boundary Movement) Rules 2008, as may be amended from time to time.

Our original submission on 9th November 2017: Replacement of DG and transformer oils is in the scope of the DG and transformer AMC contractors who have an established and statutorily approved system of onward recovery, reuse and disposal. The Township management ensures the availability and currency of statutory permissions at the time of renewal of the AMC contract. As on now, no used oil has been generated at the site for the following reasons.


b. Phase V is under construction work.

Reason stated for Non Compliance However, there seems to be production of hazardous waste in terms of used oil etc. If the PP can establish search claim they should seek suitable amendment to the condition. Till such time it may be considered not complied. Because, the condition "shall be sold off to the register recycle and any other type of hazardous waste generating from the project


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if any, shall be disposed as per the hazardous waste management handling and trans boundary movement rules 2008 as may be amended from time to time." has not been adhered to. Not complied till amendment is obtained. Action taken for Compliance by Godrej Garden City (as submitted herewith): We have a valid Authorization from the GPCB under the Hazardous Waste Rules (No. AWH-80446, dated 15/10/2016) and we are thereunder committed to dispose our hazardous waste following provisions of the Rules as-well-as, as stated in the EC condition. However, we understand that the EC condition is subject to generation of waste. We reiterate that the waste (Used oil from DGs) has not been generated as yes as the DGs have been operated for a very short duration so far.

Condition 32

Partly

Complied

The stack height of the DG Sets shall be equal to the height needed for the combined capacity of all proposed DG sets.

The gaseous emissions from the D. G. Sets shall conform to the standards prescribed by GPCB. At no time, the emission levels shall go beyond the stipulated standards.

Our original submission on 9th November 2017: All DG sets are installed in a distributed manner close to the power feeder busbars of the buildings clusters in open condition. Adherence to GPCB emissions standards has been the primary criteria for selection and procurement of the DGs. In addition, DG stack analysis shall be carried out every month. DG stack analysis Reports of last six months submitted with earlier Compliance Report. Reason stated by MoEF&CC for Partial Compliance on 30th November 2017: Regarding stack height of DG sets neither formula for calculation nor the adopted has been mentioned. However, Monitoring result has been shown to be within GPCB limits. Partly complied. Action taken for Compliance by Godrej Garden City (as submitted herewith): DG sets have been installed in open areas and not at the basements, and are not part of any building. In addition, as the power failure frequency in Ahmedabad is almost nil, DGs are run only for periodic trials. The available formula for stack height calculation of DG sets given in the CPCB Emission Regulation IV is for the DGs which are installed inside a building. The same is not applicable to the DGs as installed in the Township.


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DG sets at project site

Condition 37

Partly Complied


Our original submission on 9th November 2017: We are in the process of identifying vendor for Energy audit. The Energy audit will be carried out in accordance with the audit schedule. The recommendations will be implemented. Reason stated by MoEF&CC for Partial Compliance on 30th November 2017: The audit has not been conducted regularly. Also the recommendations have not yet been implemented. The PP also needs to enumerate the major recommendations emerged out of the audit and submit a definitive timeline their implementation. Action taken for Compliance by Godrej Garden City (as submitted herewith):

a. Energy performance of the buildings are periodically assessed by means of conducting energy audits. ECBC Compliance Analysis Reports carried out for the Project (May, 2018) are enclosed as Annex II. The Report comprehensively discuses climate analysis, passive architecture strategies followed and further to be followed, heat island effect, roof glazing and shading, ventilation analysis, etc.


c. The ECBC Compliance Analysis Reports carried out for the residential, commercial and school state that the energy performance of the buildings are better than the


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ECBC, 2007 base case, confirming that the energy efficiency measures (both active and passive) are effectively contributing to the objective of energy efficiency and optimal consumption as meant in the Environmental Clearance.

Condition 42

Partly Complied


Our original submission on 9th November 2017: There are ten entry-exist points in the Township as shown in the figure below. The main entry-exist is the one leading to the Jagatpur road further connecting to the Sarkej-Gandhinagar Ring road. At present there is lean traffic on the approach road or from inside the project site. However, a 30m road has been constructed as a central spine of the Township opening on this connecting road. To avoid direct merging of traffic on this road, a bell mouthed entrance is designed. Necessary signage/maps at all appropriate places are provided to guide the people towards exits and assembly points during the unforeseen emergency. Reason stated by MoEF&CC for Partial Compliance on 30th November 2017: It appears that the task has not been attendant to in a robust professional manner. As a way forward, the PP may appoint a town planning/ traffic management Consultant for detail and suggesting a plan for decongestion of the traffic and increase the safety. Party complied. Action taken for Compliance by Godrej Garden City (as submitted herewith): The traffic analysis and the finalisation of circulation plan was done based on an elaborate study carried out by Engineering & Planning Consultants, Mumbai before finalisation of the Master Plan. The Traffic Report prepared by M/s Engineering & Planning Consultants, Mumbai in 2008 is submitted herewith as Annex III to this Report in support of due studies having been conducted and its recommendations been followed in laying out roads and associated traffic systems in the township.


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OTHER CONDITIONS

Condition 55

Partly Complied

Environment Management Cell shall be formed during operation phase which supervise and monitor the environment related aspects of the project including performance of the Sewage Treatment Plant, incremental pollution loads on the ambient air quality, noise and water quality periodically.

Our original submission on 9th November 2017: Environment Management Cell has been formed under the supervision of respective functional area heads. EMC members in a distributed responsibility format supervise day to day functioning of pollution control systems, environmental quality at the project site, landscape development, safety issues, environmental monitoring documentation and reporting.

Reason stated by MoEF&CC for Partial Compliance on 30th November 2017: The PP is advised to recruit personnel one with environment engineering and one environment science background. Action taken for Compliance by Godrej Garden City (as submitted herewith): Mr. Dhiraj Kumar, M.Sc Environmental Science is working as Manager Safety. His Job description includes

HSE induction training for Engineers & Workers, Conducting JPSC, Rapid Audits Electrical Safety Committee Walk down, Weekly Safety Walk down with Contractors,

Participating in tool-box talks, PEP talks at work-fronts Conducting onsite training for workers & supervisors Preparing in Monthly Safety Activity/ Calendar Site Safety inspection with Project Manager Implementation Fire Fighting and Emergency Rescue plan at the Project site Inspection of PPE’s Organizing events such as World Environment Day, Safety Day, and Aids Day etc. Organizing motivational programmes Mock drill for workman safety etc.


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Facilities Management including STP and OWC Management operations involving utilities and infrastructure management and

upkeep Housekeeping Security and Safety Fire Fighting Transport Management Contract Management and Management of crisis of various emergencies.

CVs of experts in environmental management is enclosed as Annex IV. The organogram of present EMC with respective persons’ names is given below.


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Condition 63

Non Compliance

The applicant shall inform the public that the project has been accorded environmental clearance by the SEIAA and that the copies of the clearance letter are available with the GPCB and may also be seen at the Website of SEIAA/ SEAC/ GPCB. This shall be advertised within seven days from the date of the clearance letter, in at least two local newspapers that are widely circulated in the region, one of which shall be in the Gujarati language and the other in English. A copy each of the same shall be forwarded to the concerned Regional Office of the Ministry.

Our original submission on 9th November 2017: Public Notice regarding prior Environmental Clearance of Phase V was published in Times of India and Sandesh dated 7th June, 2014 immediately after the EC condition was noticed and the lapse realized. Copy of the advertisement is given below. Copy of the newspaper advertisements is given below. Copies of the advertisements were duly submitted to MoEF RO, Bhopal along with the Ist half yearly compliance report. Reason stated by MoEF&CC for Partial Compliance on 30th November 2017: It may be seen that advertisement was published after about one and a half years instead of mandated requirement of seven days. Action taken for Compliance by Godrej Garden City (as submitted herewith): Public Notice regarding prior Environmental Clearance was published immediately after the lapse was realized. This non-compliance for the intervening condition may please be condoned.

Public Notice in The Times of India (English Daily) Public Notice in Sandesh (Vernacular Daily)

Condition 64



Our original submission on 9th November 2017: Compliance reports have been dutifully submitted to RO Bhopal, SEIAA Gujarat, and SEAC Gujarat on a half-yearly frequency periodically 2013. Reason stated for Complied subject to condition by MoEF&CC on 30th November 2017: In view of the above submissions, condition may be considered complied. However, copy of last two forwarding letters in support may be provided.


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Action taken for Compliance by Godrej Garden City (as submitted herewith): Compliance reports have been regularly submitted to RO Bhopal, SEIAA Gujarat, and SEAC Gujarat on a half-yearly frequency periodically 2013. Last two forwarding letters are enclosed as Annex V.

Condition 65

Partly Complied


Our original submission on 9th November 2017: Consent to Establish (CtE) and Consolidated Consent and Authorization (CCA) have been duly obtained under Water Act, 1974, Air Act, 1981, and E (P) Act, 1986 (and Rules there under). Copy of CtE and CCA for existing operations were submitted with earlier compliance report. All the conditions given in the CCA have been adhered to. Compliance of CCA conditions are periodically submitted to the GPCB and the same are monitored by them on a regular frequency. Reason stated by MoEF&CC for Partial Compliance on 30th November 2017: The PP should have submitted a detailed compliance report off at least the major conditions to GPCB given through CtE and CCA. Action taken for Compliance by Godrej Garden City (as submitted herewith): Latest CCA compliance is enclosed as Annex VI herewith in compliance of the EC condition.

Annex IV CER Commitment Letter

th july, 2018environmentclearance.nic.in/writereaddata/online/... · jagatpur, ahmedabad by godrej...

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